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...
Rule 14(24) of the CCS (CCA) Rules does not automatically invalidate disciplinary proceedings merely because an inquiry exceeds the prescribed period without a written extension. Its time prescription is directory because it specifies no abatement or invalidation consequence; intervention requires inordinate unexplained delay, demonstrable prejudice, mala fides, or oppressive proceedings. Deferred promotion during pending proceedings alone is not legal prejudice. Approval of a charge memorandum is valid where the competent disciplinary authority considered the proposal, vigilance advice and relevant records; unsupported allegations of mechanical approval are insufficient. Preliminary fact-finding during deputation is permissible, and judicial review at the charge stage remains limited to jurisdictional error, patent illegality, mala fides, or fundamental statutory violation.
Rule 14(24) of the CCS (CCA) Rules does not automatically invalidate disciplinary proceedings merely because an inquiry exceeds the prescribed period without a written extension. Its time prescription is directory because it specifies no abatement or invalidation consequence; intervention requires inordinate unexplained delay, demonstrable prejudice, mala fides, or oppressive proceedings. Deferred promotion during pending proceedings alone is not legal prejudice. Approval of a charge memorandum is valid where the competent disciplinary authority considered the proposal, vigilance advice and relevant records; unsupported allegations of mechanical approval are insufficient. Preliminary fact-finding during deputation is permissible, and judicial review at the charge stage remains limited to jurisdictional error, patent illegality, mala fides, or fundamental statutory violation.
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