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...
Allegations concerning foreign investment in digital news media, share pricing and use of funds did not disclose cheating, criminal breach of trust or conspiracy. The Court held that online publication was not print media, no relevant cap on foreign investment applied at the time, and share valuation was made through a chartered accountant in line with FEMA fair-value requirements, with the final price reflecting a negotiated economic decision. It found no deception, entrustment or misappropriation, and no material showing an illegal agreement or scheduled offence. As the FIR did not disclose offences under Sections 406, 420 or 120B IPC, it was quashed and the linked ECIR under the PMLA also fell for want of a surviving predicate offence.
Allegations concerning foreign investment in digital news media, share pricing and use of funds did not disclose cheating, criminal breach of trust or conspiracy. The Court held that online publication was not print media, no relevant cap on foreign investment applied at the time, and share valuation was made through a chartered accountant in line with FEMA fair-value requirements, with the final price reflecting a negotiated economic decision. It found no deception, entrustment or misappropriation, and no material showing an illegal agreement or scheduled offence. As the FIR did not disclose offences under Sections 406, 420 or 120B IPC, it was quashed and the linked ECIR under the PMLA also fell for want of a surviving predicate offence.
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