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 - compounding of offence - Since in the case at hand, it is not in dispute that after passing of judgment dated 15.03.2022, parties have entered into the compromise, whereby entire amount of compensation awarded by learned court below has been paid by the petitioner-accused to the respondent-complainant, this Court while exercising power under Section 147 of the Act can proceed to compound the offence. - HC
Dishonor of Cheque - compounding of offence - Since in the case at hand, it is not in dispute that after passing of judgment dated 15.03.2022, parties have entered into the compromise, whereby entire amount of compensation awarded by learned court below has been paid by the petitioner-accused to the respondent-complainant, this Court while exercising power under Section 147 of the Act can proceed to compound the offence. - HC
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