Admissibility of electronic evidence bars undervaluation demands where printouts, retracted statements and no cross-examination leave the case unprove...
Limitation in oppression and mismanagement proceedings: prior knowledge of removal and dilution barred the challenge, with valuation directions upheld...
Insolvency professional agency governance rules amended to add nominee directors, tighten independent director eligibility, and regulate managing dire...
Safe Harbour Rules could not be applied suo motu to rework segmental trading costs where the assessee had not opted for that regime and had furnished segmental accounts with allocation keys; the Assessing Officer/Transfer Pricing Officer was directed to adopt the assessee's allocation after verification. An arm's length price of nil for intra-group services was also rejected because the Other Method requires a comparable uncontrolled transaction, which was not shown, and the services had already been aggregated and benchmarked under TNMM, making a separate adjustment a double count. The same reasoning invalidated the lumpsum licence fee adjustment and separate benchmarking of trademark fee. The penalty challenge was dismissed as premature.
Safe Harbour Rules could not be applied suo motu to rework segmental trading costs where the assessee had not opted for that regime and had furnished segmental accounts with allocation keys; the Assessing Officer/Transfer Pricing Officer was directed to adopt the assessee's allocation after verification. An arm's length price of nil for intra-group services was also rejected because the Other Method requires a comparable uncontrolled transaction, which was not shown, and the services had already been aggregated and benchmarked under TNMM, making a separate adjustment a double count. The same reasoning invalidated the lumpsum licence fee adjustment and separate benchmarking of trademark fee. The penalty challenge was dismissed as premature.
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