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...
Vicarious criminal liability under sections 276CC and 278B cannot be fastened on a former director who had resigned before the company's default period for non-filing of return arose. Form 32 and company master data showed that the director had ceased to hold office before the relevant assessment-year default, so the foundational requirement for prosecution was absent. The court therefore found no attributable offence against him, rejected reliance on compounding guidelines, and quashed the process and revisional order only as to that person while the prosecution continued against the remaining accused.
Vicarious criminal liability under sections 276CC and 278B cannot be fastened on a former director who had resigned before the company's default period for non-filing of return arose. Form 32 and company master data showed that the director had ceased to hold office before the relevant assessment-year default, so the foundational requirement for prosecution was absent. The court therefore found no attributable offence against him, rejected reliance on compounding guidelines, and quashed the process and revisional order only as to that person while the prosecution continued against the remaining accused.
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