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...
Prayer for being excused of any criminal liability and relieved of the alleged defaults complained of by the Registrar of Companies (ROC) - section 463(2) of the Companies Act, 2013 - The High court finds merit in the petitioners' argument regarding the offenses being barred by limitation under the Code of Criminal Procedure, 1973. - The court grants relief to the petitioners, excusing them from criminal liability and restraining the respondent from proceeding with criminal proceedings based on the notice dated 6th October, 2020.
Prayer for being excused of any criminal liability and relieved of the alleged defaults complained of by the Registrar of Companies (ROC) - section 463(2) of the Companies Act, 2013 - The High court finds merit in the petitioners' argument regarding the offenses being barred by limitation under the Code of Criminal Procedure, 1973. - The court grants relief to the petitioners, excusing them from criminal liability and restraining the respondent from proceeding with criminal proceedings based on the notice dated 6th October, 2020.
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