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...
Recovery of dues - Petitioner’s (bank) right as a Financial Creditor is superior to the rights under the Customs Act, 1962 or not - The High court examines the provisions of Section 142A of the Customs Act and Section 35 of the SARFAESI Act to determine the legality of the letter from the DRI. It concludes that the actions initiated by the petitioner under the SARFAESI Act cannot be impeded by the letter from DRI.
Recovery of dues - Petitioner’s (bank) right as a Financial Creditor is superior to the rights under the Customs Act, 1962 or not - The High court examines the provisions of Section 142A of the Customs Act and Section 35 of the SARFAESI Act to determine the legality of the letter from the DRI. It concludes that the actions initiated by the petitioner under the SARFAESI Act cannot be impeded by the letter from DRI.
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