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 - vicarious liability of the director - appellant was in-charge of day-to-day affairs of the Company or not - The appellant argued against her vicarious liability under Section 138 of the Negotiable Instruments Act, contending that she was not involved in the company's day-to-day affairs and was not a signatory to the cheques in question. The court found the allegations insufficient to establish the appellant's liability and quashed the proceedings against her. - Mere directorship does not automatically entail liability. - The court noted that the complaint lacked specific averments demonstrating how the appellant was in charge of the company's day-to-day affairs or responsible for its conduct.
Dishonour of Cheque - vicarious liability of the director - appellant was in-charge of day-to-day affairs of the Company or not - The appellant argued against her vicarious liability under Section 138 of the Negotiable Instruments Act, contending that she was not involved in the company's day-to-day affairs and was not a signatory to the cheques in question. The court found the allegations insufficient to establish the appellant's liability and quashed the proceedings against her. - Mere directorship does not automatically entail liability. - The court noted that the complaint lacked specific averments demonstrating how the appellant was in charge of the company's day-to-day affairs or responsible for its conduct.
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