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...
Personal insolvency interim moratorium does not stay cheque-dishonour prosecutions against company directors and responsible persons where the dishonoured cheques represent the company's debt. Directors are prosecuted through statutory vicarious liability rather than as primary personal debtors, while the moratorium applies to civil debt-recovery actions concerning the individual debtor and does not bar criminal proceedings. Potential recovery of compensation does not justify staying the trial at that stage. A pending reference to a larger Bench does not weaken the binding effect of existing law unless altered; therefore, trials need not await determination of questions concerning compensation. Applications and writ petitions seeking to stay or defer the prosecutions were dismissed, and interim stays were vacated.
Personal insolvency interim moratorium does not stay cheque-dishonour prosecutions against company directors and responsible persons where the dishonoured cheques represent the company's debt. Directors are prosecuted through statutory vicarious liability rather than as primary personal debtors, while the moratorium applies to civil debt-recovery actions concerning the individual debtor and does not bar criminal proceedings. Potential recovery of compensation does not justify staying the trial at that stage. A pending reference to a larger Bench does not weaken the binding effect of existing law unless altered; therefore, trials need not await determination of questions concerning compensation. Applications and writ petitions seeking to stay or defer the prosecutions were dismissed, and interim stays were vacated.
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