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...
Dishonour of Cheque - applicability of principles of discharge - allegations of taking the amount on the pretext of Chinese technology - Forged documents and cheating - The High Court held that while the case under Section 138 of the Negotiable Instruments Act was not made out, a prima facie case under Sections 406 and 420 of the Indian Penal Code existed. Consequently, the petition was allowed in part, with the petitioner discharged from liability under Section 138 of the Negotiable Instruments Act but facing further proceedings under Sections 406 and 420 of the Indian Penal Code.
Dishonour of Cheque - applicability of principles of discharge - allegations of taking the amount on the pretext of Chinese technology - Forged documents and cheating - The High Court held that while the case under Section 138 of the Negotiable Instruments Act was not made out, a prima facie case under Sections 406 and 420 of the Indian Penal Code existed. Consequently, the petition was allowed in part, with the petitioner discharged from liability under Section 138 of the Negotiable Instruments Act but facing further proceedings under Sections 406 and 420 of the Indian Penal Code.
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