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...
Clean-hands requirements in PIL jurisdiction require complete disclosure of earlier similar proceedings to prevent parallel litigation and conflicting adjudication. Failure to disclose a pending writ petition seeking substantially overlapping relief concerning NSE shareholding and beneficial ownership was treated as suppression of material facts, forum shopping and abuse of process. The High Court dismissed the PIL at the threshold without examining divestment allegations and imposed exemplary costs, as the conduct disentitled the petitioner to equitable and extraordinary relief irrespective of the underlying merits.
Clean-hands requirements in PIL jurisdiction require complete disclosure of earlier similar proceedings to prevent parallel litigation and conflicting adjudication. Failure to disclose a pending writ petition seeking substantially overlapping relief concerning NSE shareholding and beneficial ownership was treated as suppression of material facts, forum shopping and abuse of process. The High Court dismissed the PIL at the threshold without examining divestment allegations and imposed exemplary costs, as the conduct disentitled the petitioner to equitable and extraordinary relief irrespective of the underlying merits.
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