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...
Import of goods - infringement of the Intellectual Property Rights of the plaintiffs - eeking impleadment in the present suit as a proper party - Infringement of trade marks - violation of paragraph 2.3 of the Foreign Trade Policy, 2015-20 - in terms of Rule 11 of IPR Enforcement Rules, the applicant cannot go into the question of infringement till the final adjudication of the present suit - The applicant is neither a necessary party nor a proper party for the adjudication of the suit. - HC
Import of goods - infringement of the Intellectual Property Rights of the plaintiffs - eeking impleadment in the present suit as a proper party - Infringement of trade marks - violation of paragraph 2.3 of the Foreign Trade Policy, 2015-20 - in terms of Rule 11 of IPR Enforcement Rules, the applicant cannot go into the question of infringement till the final adjudication of the present suit - The applicant is neither a necessary party nor a proper party for the adjudication of the suit. - HC
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