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...
Recovery of tax arrears from the Former director of the Company - Attachment of Bank accounts - DIN of the petitioner got disqualified under Section 164(2)(a) of the Companies Act, 2013 - The High Court found that the attachment order was issued without proper consideration of the petitioner's status and without affording them an opportunity to present their case. The court held that this violated the petitioner's rights under Article 14 and 300A of the Constitution. - The High Court accepted the petitioner's argument that they had resigned from their directorship before the relevant period. As such, the court ruled that the petitioner could not be held liable for the company's tax dues during that period.
Recovery of tax arrears from the Former director of the Company - Attachment of Bank accounts - DIN of the petitioner got disqualified under Section 164(2)(a) of the Companies Act, 2013 - The High Court found that the attachment order was issued without proper consideration of the petitioner's status and without affording them an opportunity to present their case. The court held that this violated the petitioner's rights under Article 14 and 300A of the Constitution. - The High Court accepted the petitioner's argument that they had resigned from their directorship before the relevant period. As such, the court ruled that the petitioner could not be held liable for the company's tax dues during that period.
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