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...
Professional misconduct - Debarment from being appointed as an auditor or internal auditor or from undertaking any audit - levy of penalty - The court observed that the audit committee's conclusion was based solely on EP's presentation, which ruled out fraud reported by PW. The management used PHD's work as a disclosure in the financial statements, which were then audited by PHD, amounting to self-review. The court found no ground to grant any interim relief at this stage and rejected the applications for interim direction.
Professional misconduct - Debarment from being appointed as an auditor or internal auditor or from undertaking any audit - levy of penalty - The court observed that the audit committee's conclusion was based solely on EP's presentation, which ruled out fraud reported by PW. The management used PHD's work as a disclosure in the financial statements, which were then audited by PHD, amounting to self-review. The court found no ground to grant any interim relief at this stage and rejected the applications for interim direction.
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