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...
An express statutory bar under the Income-tax Act excludes relief under Section 360 Cr.P.C. and the Probation of Offenders Act for a person convicted of an offence under the Act, except where the person is under eighteen years of age. A person convicted under Section 277 could therefore not lawfully be released on probation. The probation order was set aside, the conviction remained undisturbed, and the matter was remitted to the trial court for fresh consideration of sentence only after hearing both sides.
An express statutory bar under the Income-tax Act excludes relief under Section 360 Cr.P.C. and the Probation of Offenders Act for a person convicted of an offence under the Act, except where the person is under eighteen years of age. A person convicted under Section 277 could therefore not lawfully be released on probation. The probation order was set aside, the conviction remained undisturbed, and the matter was remitted to the trial court for fresh consideration of sentence only after hearing both sides.
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