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...
Depositories are not confined to mechanical record-keeping; under the Depositories Act, the 2018 Regulations and approved bye-laws, they owe investor-protection and supervisory duties, including vigilance through enhanced supervision and an early warning mechanism. On the facts described, failure to detect dormant-account movement, off-market transfers and the subsequent pledge of client securities amounted to negligence, so the beneficial owner was entitled to indemnification and the depository could recover from the participant, who acted within the depository framework as the depository's agent. On appellate review, Section 37 permitted no reappreciation where the arbitral award and Section 34 order rested on evidence, disclosed reasons and a plausible view, so interference was refused.
Depositories are not confined to mechanical record-keeping; under the Depositories Act, the 2018 Regulations and approved bye-laws, they owe investor-protection and supervisory duties, including vigilance through enhanced supervision and an early warning mechanism. On the facts described, failure to detect dormant-account movement, off-market transfers and the subsequent pledge of client securities amounted to negligence, so the beneficial owner was entitled to indemnification and the depository could recover from the participant, who acted within the depository framework as the depository's agent. On appellate review, Section 37 permitted no reappreciation where the arbitral award and Section 34 order rested on evidence, disclosed reasons and a plausible view, so interference was refused.
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