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...
Registrar's statutory power to frame service rules includes the power to amend, vary or rescind them. Deletion of a service-rule bar preventing technical employees from promotion to non-technical posts remains valid where ordered by the Registrar; a communication issued by an Additional Registrar may convey that decision, and its nomenclature as a circular does not displace the underlying statutory authority. A statutory requirement to lay amended rules before the Legislative Assembly is directory, despite use of "shall", where no consequence follows from non-laying. Non-compliance therefore does not invalidate the amendment or a promotion made under it.
Registrar's statutory power to frame service rules includes the power to amend, vary or rescind them. Deletion of a service-rule bar preventing technical employees from promotion to non-technical posts remains valid where ordered by the Registrar; a communication issued by an Additional Registrar may convey that decision, and its nomenclature as a circular does not displace the underlying statutory authority. A statutory requirement to lay amended rules before the Legislative Assembly is directory, despite use of "shall", where no consequence follows from non-laying. Non-compliance therefore does not invalidate the amendment or a promotion made under it.
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