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...
Compounding of a cheque dishonour complaint may be pursued where the dispute is monetary and the accused seeks amicable settlement, with the trial court to act on the basis of the Supreme Court guidelines in Damodar S. Prabhu and later guidance. The accused was permitted to approach the trial court for compounding on deposit of 10% of the cheque amount, and the court below was to pass appropriate orders in accordance with law. No coercive measures were to be taken during the limited period granted for seeking compounding, but if the accused failed to appear, the trial court could proceed against him in accordance with law.
Compounding of a cheque dishonour complaint may be pursued where the dispute is monetary and the accused seeks amicable settlement, with the trial court to act on the basis of the Supreme Court guidelines in Damodar S. Prabhu and later guidance. The accused was permitted to approach the trial court for compounding on deposit of 10% of the cheque amount, and the court below was to pass appropriate orders in accordance with law. No coercive measures were to be taken during the limited period granted for seeking compounding, but if the accused failed to appear, the trial court could proceed against him in accordance with law.
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