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...
Seeking exemption from pre-litigation mediation, as required by Section 12-A of the Commercial Courts Act, 2015 - Proceedings u/s 138 of the Negotiable Instruments Act, 1881 - suit for recovery alongwith interest and future interest - However, the court found no evidence of a failed mediation attempt and dismissed the application for exemption. The court also rejected the plaint, stating that pre-litigation mediation is mandatory unless urgent interim relief is sought. The appellant was given liberty to file a fresh suit after complying with the provisions of Section 12-A of the Commercial Courts Act, 2015.
Seeking exemption from pre-litigation mediation, as required by Section 12-A of the Commercial Courts Act, 2015 - Proceedings u/s 138 of the Negotiable Instruments Act, 1881 - suit for recovery alongwith interest and future interest - However, the court found no evidence of a failed mediation attempt and dismissed the application for exemption. The court also rejected the plaint, stating that pre-litigation mediation is mandatory unless urgent interim relief is sought. The appellant was given liberty to file a fresh suit after complying with the provisions of Section 12-A of the Commercial Courts Act, 2015.
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