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...
Dishonor of Cheque - legally enforceable debt or not - Since the accused rebutted the presumption whatever arisen by adducing oral and documentary evidence, the onus shifts again on the complainant to prove his financial capacity by adducing oral evidence, more particularly, when it is the case of giving loan by cash - In the present case, the complainant has miserably failed to discharge the burden cast on him and there is no cogent evidence to believe that the accused had, in fact, issued the alleged cheque in favour of the complainant towards discharge of legally enforceable debt. - HC
Dishonor of Cheque - legally enforceable debt or not - Since the accused rebutted the presumption whatever arisen by adducing oral and documentary evidence, the onus shifts again on the complainant to prove his financial capacity by adducing oral evidence, more particularly, when it is the case of giving loan by cash - In the present case, the complainant has miserably failed to discharge the burden cast on him and there is no cogent evidence to believe that the accused had, in fact, issued the alleged cheque in favour of the complainant towards discharge of legally enforceable debt. - HC
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