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...
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Inordinate delay of more than 2100 days in filing revisions was not condoned because the revisionists offered no plausible explanation, had absconded after conviction, and had shown disregard for the court process. Despite that, the High Court set aside the non-speaking appellate judgments because the criminal appeals had been decided in the appellants' absence without appointment of amicus curiae and without the required scrutiny of the record and trial court reasoning. Applying the rule in Bani Singh and related authorities, the Court held that such defective disposal could not stand and revived the appeals for fresh hearing on merits, subject to deposit of part of the fine and payment of costs.
Inordinate delay of more than 2100 days in filing revisions was not condoned because the revisionists offered no plausible explanation, had absconded after conviction, and had shown disregard for the court process. Despite that, the High Court set aside the non-speaking appellate judgments because the criminal appeals had been decided in the appellants' absence without appointment of amicus curiae and without the required scrutiny of the record and trial court reasoning. Applying the rule in Bani Singh and related authorities, the Court held that such defective disposal could not stand and revived the appeals for fresh hearing on merits, subject to deposit of part of the fine and payment of costs.
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