Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Insolvency moratorium does not shield company officers from cheque dishonour prosecution for liability arising before corporate insolvency proceedings...
Reassessment beyond four years following an assessment under section 143(3) requires failure by the taxpayer to make a full and true disclosure of material facts. The notes state that where the subsidy was disclosed in the financial statements and considered originally, reopening without fresh material constitutes a change of opinion and is invalid. For transfer-pricing benchmarking, an associated enterprise subsidy that routinely compensates unabsorbed distribution costs and is directly linked to distribution operations is treated as operating income. Such subsidy must be included when benchmarking closely linked distribution transactions, rather than excluded in making a transfer-pricing adjustment.
Reassessment beyond four years following an assessment under section 143(3) requires failure by the taxpayer to make a full and true disclosure of material facts. The notes state that where the subsidy was disclosed in the financial statements and considered originally, reopening without fresh material constitutes a change of opinion and is invalid. For transfer-pricing benchmarking, an associated enterprise subsidy that routinely compensates unabsorbed distribution costs and is directly linked to distribution operations is treated as operating income. Such subsidy must be included when benchmarking closely linked distribution transactions, rather than excluded in making a transfer-pricing adjustment.
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