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...
Statutory presumptions under Sections 118 and 139 of the N.I. Act arose once the cheque and signature were proved, and the accused's bare plea of non-issuance, unsupported by expert evidence, witnesses, or credible material, failed to rebut the presumption of a legally enforceable debt on the preponderance of probabilities. The bank return memo also carried the statutory presumption of correctness under Section 146, so the objection that no bank official was examined was rejected. The High Court further held that revisional interference with concurrent findings is confined to patent illegality, perversity, or miscarriage of justice; finding none, it upheld the conviction and dismissed the revision.
Statutory presumptions under Sections 118 and 139 of the N.I. Act arose once the cheque and signature were proved, and the accused's bare plea of non-issuance, unsupported by expert evidence, witnesses, or credible material, failed to rebut the presumption of a legally enforceable debt on the preponderance of probabilities. The bank return memo also carried the statutory presumption of correctness under Section 146, so the objection that no bank official was examined was rejected. The High Court further held that revisional interference with concurrent findings is confined to patent illegality, perversity, or miscarriage of justice; finding none, it upheld the conviction and dismissed the revision.
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