Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
ITAT held that omission to mention a Document Identification Number in the initiating notice did not invalidate the proceeding, because the retrospective validation under section 292BA cures a mere mistake, defect or omission where the order is otherwise referenced by DIN; the assessee's objection also had not been raised before the first appellate authority. On the penalty for cash acceptance, the Tribunal held that section 269SS applies only to receipt of a loan or deposit, not to repayment of earlier advances, but the factual nature of the receipts was not established on record. The matter was therefore remanded for fresh adjudication after giving the assessee one further opportunity to produce evidence.
ITAT held that omission to mention a Document Identification Number in the initiating notice did not invalidate the proceeding, because the retrospective validation under section 292BA cures a mere mistake, defect or omission where the order is otherwise referenced by DIN; the assessee's objection also had not been raised before the first appellate authority. On the penalty for cash acceptance, the Tribunal held that section 269SS applies only to receipt of a loan or deposit, not to repayment of earlier advances, but the factual nature of the receipts was not established on record. The matter was therefore remanded for fresh adjudication after giving the assessee one further opportunity to produce evidence.
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