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...
Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent forensic audit. It emphasized the necessity of recording reasons to support judicial orders, citing legal precedents. Despite oral submissions, the Appellant failed to file a reply affidavit or supporting documents, leaving the interim order based solely on the petitioner's averments. The Tribunal upheld the interim order for a forensic audit, considering allegations of serious lapses and non-compliance in financial statements and statutory compliances.
Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent forensic audit. It emphasized the necessity of recording reasons to support judicial orders, citing legal precedents. Despite oral submissions, the Appellant failed to file a reply affidavit or supporting documents, leaving the interim order based solely on the petitioner's averments. The Tribunal upheld the interim order for a forensic audit, considering allegations of serious lapses and non-compliance in financial statements and statutory compliances.
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