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...
Dishonor of cheques - Condonation of delay of 1259 days in filing the complaint for an offence punishable u/s 138 of the Negotiable Instruments Act, 1881 - Exercise of Discretion by Lower Courts- sufficient reason to condone the delay or not - The High courts uphold the discretion exercised by the lower courts, emphasizing the importance of balancing procedural requirements with substantive justice. - Various legal principles and precedents are cited and analyzed throughout the proceedings, including the liberal interpretation of the concept of "sufficient cause" for condonation of delay and the significance of balancing substantive justice with procedural requirements. - Ultimately, the court dismisses the petition, affirming the lower courts' exercise of discretion to condone the delay.
Dishonor of cheques - Condonation of delay of 1259 days in filing the complaint for an offence punishable u/s 138 of the Negotiable Instruments Act, 1881 - Exercise of Discretion by Lower Courts- sufficient reason to condone the delay or not - The High courts uphold the discretion exercised by the lower courts, emphasizing the importance of balancing procedural requirements with substantive justice. - Various legal principles and precedents are cited and analyzed throughout the proceedings, including the liberal interpretation of the concept of "sufficient cause" for condonation of delay and the significance of balancing substantive justice with procedural requirements. - Ultimately, the court dismisses the petition, affirming the lower courts' exercise of discretion to condone the delay.
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