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 - issuance of statutory notice to proper person or not - acquittal of accused - The High Court noted a misunderstanding by the trial court regarding the management of the company by its directors and the legal implications thereof. The statutory notice was not properly issued to the company along with its director, leading to procedural discrepancies. Despite acknowledging errors in the trial court's judgment, the High Court upheld the acquittal based on procedural faults in issuing the statutory notice.
Dishonour of Cheque - issuance of statutory notice to proper person or not - acquittal of accused - The High Court noted a misunderstanding by the trial court regarding the management of the company by its directors and the legal implications thereof. The statutory notice was not properly issued to the company along with its director, leading to procedural discrepancies. Despite acknowledging errors in the trial court's judgment, the High Court upheld the acquittal based on procedural faults in issuing the statutory notice.
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