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...
Maintainability of petition - seeking relief from Bail conditions - GST fraud - The litigant should adopt a proper mechanism provided under the law for redressal of his grievances, instead of not doing so and rushing to this Court asking it to interfere in the matter, exercising the power under Section 482 Cr.P.C. If such practice is allowed, then the litigants would rush to this court moving petitions under Section 482 Cr.P.C., in a hope to get early decision, instead of availing of the remedy provided under the law - HC
Maintainability of petition - seeking relief from Bail conditions - GST fraud - The litigant should adopt a proper mechanism provided under the law for redressal of his grievances, instead of not doing so and rushing to this Court asking it to interfere in the matter, exercising the power under Section 482 Cr.P.C. If such practice is allowed, then the litigants would rush to this court moving petitions under Section 482 Cr.P.C., in a hope to get early decision, instead of availing of the remedy provided under the law - HC
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