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...
Territorial jurisdiction under Article 226(2) was not made out for a writ challenging NCLT, Delhi proceedings initiating personal insolvency against a guarantor. The relevant cause of action arose from proceedings under the Insolvency and Bankruptcy Code, and Section 60 placed the Adjudicating Authority in the NCLT having jurisdiction over the corporate person's registered office. As that office was in New Delhi, the fact that the credit facility had been availed in Kerala did not confer jurisdiction on the Kerala High Court. The writ petition was dismissed as not maintainable for want of territorial jurisdiction, and the alternate-remedy objection was left unexamined.
Territorial jurisdiction under Article 226(2) was not made out for a writ challenging NCLT, Delhi proceedings initiating personal insolvency against a guarantor. The relevant cause of action arose from proceedings under the Insolvency and Bankruptcy Code, and Section 60 placed the Adjudicating Authority in the NCLT having jurisdiction over the corporate person's registered office. As that office was in New Delhi, the fact that the credit facility had been availed in Kerala did not confer jurisdiction on the Kerala High Court. The writ petition was dismissed as not maintainable for want of territorial jurisdiction, and the alternate-remedy objection was left unexamined.
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