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...
Whether the legal services provided by lawyers are covered under the Consumer Protection Act, 1986 (now Consumer Protection Act, 2019). - The court concluded that the services provided by advocates are under a "contract of personal service" due to the significant control clients have over the manner in which advocates render their services. Consequently, such services are excluded from the definition of "service" under the CP Act, 2019, and therefore, a complaint alleging "deficiency in service" against advocates is not maintainable under this Act.
Whether the legal services provided by lawyers are covered under the Consumer Protection Act, 1986 (now Consumer Protection Act, 2019). - The court concluded that the services provided by advocates are under a "contract of personal service" due to the significant control clients have over the manner in which advocates render their services. Consequently, such services are excluded from the definition of "service" under the CP Act, 2019, and therefore, a complaint alleging "deficiency in service" against advocates is not maintainable under this Act.
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