Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Penalty for an alleged failure to furnish transfer-pricing documentation relating to purchases from an alleged associated enterprise was deleted after the underlying transfer-pricing adjustment was removed. The penalty's foundation consequently ceased to exist. Applying an earlier Tribunal decision on identical facts and the principle of consistency, the deletion was sustained and the Revenue's challenge was dismissed. The taxpayer's cross-objection was dismissed as infructuous.
Penalty for an alleged failure to furnish transfer-pricing documentation relating to purchases from an alleged associated enterprise was deleted after the underlying transfer-pricing adjustment was removed. The penalty's foundation consequently ceased to exist. Applying an earlier Tribunal decision on identical facts and the principle of consistency, the deletion was sustained and the Revenue's challenge was dismissed. The taxpayer's cross-objection was dismissed as infructuous.
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TaxTMI 
TaxTMI 
