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...
SEBI Act offences involving front running must be prosecuted through a complaint filed by SEBI before the competent court, because section 26 bars cognizance on an investor's FIR. Front running involves using non-public information about impending substantial securities transactions to obtain wrongful gains and falls within the specialised securities-market regime. That regime prevails over general penal law where the FIR's allegations essentially constitute the SEBI offence, preventing circumvention through ordinary criminal registration. The FIR was quashed in its existing form, while leaving SEBI free to consider criminal action under the SEBI Act and preserving any independent remedies or distinct IPC/BNS offences.
SEBI Act offences involving front running must be prosecuted through a complaint filed by SEBI before the competent court, because section 26 bars cognizance on an investor's FIR. Front running involves using non-public information about impending substantial securities transactions to obtain wrongful gains and falls within the specialised securities-market regime. That regime prevails over general penal law where the FIR's allegations essentially constitute the SEBI offence, preventing circumvention through ordinary criminal registration. The FIR was quashed in its existing form, while leaving SEBI free to consider criminal action under the SEBI Act and preserving any independent remedies or distinct IPC/BNS offences.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
