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 restoration of name of the company on ROC - failure to file the Financial Statement and Annual Returns since incorporation - Section 252 of Companies Act, 2013 - The Appellate Tribunal noted that while the appellant had filed financial statements until 2015-16, there was a gap in filings for the subsequent years. However, the appellant had produced independent auditor reports for the missing years, demonstrating substantial assets and indicating a bonafide intention to comply. - Considering the appellant's substantial assets, the Tribunal found it just and equitable to restore the company's name to the Register of Companies. They emphasized that the appellant was not a shell company or engaged in fund siphoning, and the restoration would not prejudice the Registrar of Companies.
Seeking restoration of name of the company on ROC - failure to file the Financial Statement and Annual Returns since incorporation - Section 252 of Companies Act, 2013 - The Appellate Tribunal noted that while the appellant had filed financial statements until 2015-16, there was a gap in filings for the subsequent years. However, the appellant had produced independent auditor reports for the missing years, demonstrating substantial assets and indicating a bonafide intention to comply. - Considering the appellant's substantial assets, the Tribunal found it just and equitable to restore the company's name to the Register of Companies. They emphasized that the appellant was not a shell company or engaged in fund siphoning, and the restoration would not prejudice the Registrar of Companies.
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