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...
Attachment of Properties - The Custodian sought to recover significant sums from different individuals or entities, claiming they were indebted to the notified party. - The Special Court directed the appellant to pay a sum of Rs. 50 lakhs with Interest - diversion of funds from the banks/FIs to the individual accounts of certain brokers - The Supreme Court addressed several key issues arising from the appeals under the Act of 1992, including the notification of individuals, recovery of dues, and the burden of proof. It clarified that property attachment under the Act occurs from the date of notification forward, not retroactively. The SC found it insufficient to establish the appellants' liabilities. Moreover, it emphasized the Custodian's responsibility to prove the debts before shifting the burden onto the appellants. Consequently, the Court ruled in favor of the appellants, quashing the judgments and allowing the appeals.
Attachment of Properties - The Custodian sought to recover significant sums from different individuals or entities, claiming they were indebted to the notified party. - The Special Court directed the appellant to pay a sum of Rs. 50 lakhs with Interest - diversion of funds from the banks/FIs to the individual accounts of certain brokers - The Supreme Court addressed several key issues arising from the appeals under the Act of 1992, including the notification of individuals, recovery of dues, and the burden of proof. It clarified that property attachment under the Act occurs from the date of notification forward, not retroactively. The SC found it insufficient to establish the appellants' liabilities. Moreover, it emphasized the Custodian's responsibility to prove the debts before shifting the burden onto the appellants. Consequently, the Court ruled in favor of the appellants, quashing the judgments and allowing the appeals.
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