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...
The High Court analyzed evidence in a case involving dishonored cheques. The court emphasized the need to rebut the presumption u/s 139 of the Negotiable Instruments Act. The petitioner failed to prove the origin of the loan amount and the purpose of issuing the cheques. The respondent successfully demonstrated that the cheques were not for a legally enforceable debt. As a result, the petitioner's appeal was deemed futile, and the court upheld the lower court's decision, dismissing the petition. The High Court clarified its authority to reevaluate evidence but stressed the need for a justifiable basis for interference with trial court decisions.
The High Court analyzed evidence in a case involving dishonored cheques. The court emphasized the need to rebut the presumption u/s 139 of the Negotiable Instruments Act. The petitioner failed to prove the origin of the loan amount and the purpose of issuing the cheques. The respondent successfully demonstrated that the cheques were not for a legally enforceable debt. As a result, the petitioner's appeal was deemed futile, and the court upheld the lower court's decision, dismissing the petition. The High Court clarified its authority to reevaluate evidence but stressed the need for a justifiable basis for interference with trial court decisions.
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