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...
Rejection of bid - requirement of uploading annual turnover certificate issued by the Chartered Accountant for the last five financial years bearing UDIN of Institute of Chartered Accountants of India (ICAI) - The Court found that the stipulation for submitting a five-year annual turnover certificate with UDIN by Chartered Accountants was mandatory. The absence of UDIN was grounds for rejection, and this requirement was repeatedly emphasized in the tender documents. - The Court criticized the Technical Evaluation Committee's reconsideration favoring Respondent No. 5 as unfair, arbitrary, and biased. It noted that the Committee's reliance on documents not meeting the UDIN requirement was illegal and overlooked the mandatory nature of the tender conditions.
Rejection of bid - requirement of uploading annual turnover certificate issued by the Chartered Accountant for the last five financial years bearing UDIN of Institute of Chartered Accountants of India (ICAI) - The Court found that the stipulation for submitting a five-year annual turnover certificate with UDIN by Chartered Accountants was mandatory. The absence of UDIN was grounds for rejection, and this requirement was repeatedly emphasized in the tender documents. - The Court criticized the Technical Evaluation Committee's reconsideration favoring Respondent No. 5 as unfair, arbitrary, and biased. It noted that the Committee's reliance on documents not meeting the UDIN requirement was illegal and overlooked the mandatory nature of the tender conditions.
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