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...
Violation under FERA - charge u/s. 56 of FERA - Company being in Liquidation - Whether the charge against the Company can be framed through the petitioner? - Petitioner had resigned from the Company in the year 1993, that is, much before the alleged transaction that took place in 1997. - The court concludes that the trial court erred in framing the charge against the company through the petitioner. It orders modification of the impugned order to reflect that the charge against the company should be through the Provisional Liquidator. However, it clarifies that the charges framed against the petitioner in his individual capacity remain unaffected.
Violation under FERA - charge u/s. 56 of FERA - Company being in Liquidation - Whether the charge against the Company can be framed through the petitioner? - Petitioner had resigned from the Company in the year 1993, that is, much before the alleged transaction that took place in 1997. - The court concludes that the trial court erred in framing the charge against the company through the petitioner. It orders modification of the impugned order to reflect that the charge against the company should be through the Provisional Liquidator. However, it clarifies that the charges framed against the petitioner in his individual capacity remain unaffected.
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