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...
The alleged joint business arrangement, supply transactions and supporting documents were not proved, so the civil money claim failed and the recovery suit was dismissed. The agreement and related documents were found unreliable because the date was inconsistent with the stamp paper purchase, delivery of materials was not established through supporting witnesses, and several connecting documents were treated as fabricated. Testimony already examined and cross-examined could not be wholly eschewed merely because later cross-examination did not occur, and its probative value had to be assessed. In the cheque dishonour matter, the accused failed to rebut the statutory presumption of a legally enforceable debt, so the acquittal was set aside and the conviction and sentence restored.
The alleged joint business arrangement, supply transactions and supporting documents were not proved, so the civil money claim failed and the recovery suit was dismissed. The agreement and related documents were found unreliable because the date was inconsistent with the stamp paper purchase, delivery of materials was not established through supporting witnesses, and several connecting documents were treated as fabricated. Testimony already examined and cross-examined could not be wholly eschewed merely because later cross-examination did not occur, and its probative value had to be assessed. In the cheque dishonour matter, the accused failed to rebut the statutory presumption of a legally enforceable debt, so the acquittal was set aside and the conviction and sentence restored.
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