Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Page of 4916
Press 'Enter' after typing page number.
501 to 520 of 98302 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Penalty under Explanation 7 to section 271(1)(c) was not sustainable on a transfer pricing adjustment where the taxpayer used the prescribed TNMM method, disclosed its filters, comparables and operating-margin computation, and acted in good faith with due diligence. Differences over the profit level indicator and treatment of operating items were debatable interpretational issues, not evidence that the arm's length price had been computed outside the statutory framework. Mere differences of opinion on such issues do not attract penalty. The High Court sustained deletion of the penalty and dismissed the Revenue's appeal for want of a substantial question of law.
Penalty under Explanation 7 to section 271(1)(c) was not sustainable on a transfer pricing adjustment where the taxpayer used the prescribed TNMM method, disclosed its filters, comparables and operating-margin computation, and acted in good faith with due diligence. Differences over the profit level indicator and treatment of operating items were debatable interpretational issues, not evidence that the arm's length price had been computed outside the statutory framework. Mere differences of opinion on such issues do not attract penalty. The High Court sustained deletion of the penalty and dismissed the Revenue's appeal for want of a substantial question of law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
