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 dues of the company from personal assets of the Director - Application of the doctrine of lifting the corporate veil - vicarious liability of petitioner to discharge the tax dues of the Company-under-Liquidation - The court concluded that the petitioner could not be held personally liable for the tax dues of the Company-under-Liquidation as there was no evidence to justify lifting the corporate veil.
Recovery of tax dues of the company from personal assets of the Director - Application of the doctrine of lifting the corporate veil - vicarious liability of petitioner to discharge the tax dues of the Company-under-Liquidation - The court concluded that the petitioner could not be held personally liable for the tax dues of the Company-under-Liquidation as there was no evidence to justify lifting the corporate veil.
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