Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
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...
Cancellation of a mandi shop allotment for alleged failure to deposit 50% of the bid amount was found unsustainable where the remaining amount had been paid on behalf of the allottee and its receipt by the authority was undisputed. The Court treated this as substantial compliance with the payment condition and held that the allotment could not be cancelled on the premise of non-payment. The cancellation order and revisional order were set aside, and allotment of the shop in favour of the petitioner was directed.
Cancellation of a mandi shop allotment for alleged failure to deposit 50% of the bid amount was found unsustainable where the remaining amount had been paid on behalf of the allottee and its receipt by the authority was undisputed. The Court treated this as substantial compliance with the payment condition and held that the allotment could not be cancelled on the premise of non-payment. The cancellation order and revisional order were set aside, and allotment of the shop in favour of the petitioner was directed.
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