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...
Dishonour of cheque due to insufficient funds - no vicarious liability u/s 141 NI Act. Petitioner not shown as partner in firm through certificate from Deputy Registrar of Firms. Cheque issued by firm, signed by Sh. Hoshiyar Singh, not petitioner. No evidence petitioner was partner or signatory. Forcing petitioner to stand trial solely on unsubstantiated averment would be abuse of process. Petition allowed considering factual matrix and unimpeachable material presented by petitioner.
Dishonour of cheque due to insufficient funds - no vicarious liability u/s 141 NI Act. Petitioner not shown as partner in firm through certificate from Deputy Registrar of Firms. Cheque issued by firm, signed by Sh. Hoshiyar Singh, not petitioner. No evidence petitioner was partner or signatory. Forcing petitioner to stand trial solely on unsubstantiated averment would be abuse of process. Petition allowed considering factual matrix and unimpeachable material presented by petitioner.
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