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...
Tribunal jurisdiction to convene a requisitioned extraordinary general meeting is not conditional on the requisitioning member first using its statutory power to call the meeting after Board default; those remedies operate independently. However, intervention in corporate internal management remains exceptional and requires a reasonable factual basis showing that convening the meeting through ordinary statutory or articles-based mechanisms is impracticable. Board division or rejection of a requisition alone does not establish impracticability. Where the requisitioning member neither demonstrates difficulty in convening shareholders nor uses the available statutory mechanism, a direction to convene the meeting lacks the required factual basis and should be set aside.
Tribunal jurisdiction to convene a requisitioned extraordinary general meeting is not conditional on the requisitioning member first using its statutory power to call the meeting after Board default; those remedies operate independently. However, intervention in corporate internal management remains exceptional and requires a reasonable factual basis showing that convening the meeting through ordinary statutory or articles-based mechanisms is impracticable. Board division or rejection of a requisition alone does not establish impracticability. Where the requisitioning member neither demonstrates difficulty in convening shareholders nor uses the available statutory mechanism, a direction to convene the meeting lacks the required factual basis and should be set aside.
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