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...
Allegations of custodial assault during summons proceedings and coerced confession were not substantiated where no independent contemporaneous material linked the claimed injuries to the relevant date. The respondents denied the incident and relied on CCTV footage, contemporaneous records and an incident report, while the absence of any complaint during the proceedings, any request for medical aid at the premises, or any immediate police complaint weighed against the claim. On that record, writ relief was declined and the petition dismissed.
Allegations of custodial assault during summons proceedings and coerced confession were not substantiated where no independent contemporaneous material linked the claimed injuries to the relevant date. The respondents denied the incident and relied on CCTV footage, contemporaneous records and an incident report, while the absence of any complaint during the proceedings, any request for medical aid at the premises, or any immediate police complaint weighed against the claim. On that record, writ relief was declined and the petition dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
