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...
Transfer of 7000 equity shares - prohibitory order u/s 45MB (2) of RBI Act - Admitted possession of 4000 shares certificates and transfer deeds by Anoop Jain - Issue of consideration for 4000 shares - Anoop Jain relied on Delhi stock exchange register for payment of consideration - Appellants objected discrepancy in timeline of sale by appellant No. 1 and purchase by respondents, lack of proof of consideration payment - Matter remanded to Company Court to inquire when 4000 shares sold to Anoop Jain, 1500, 900 and 600 shares sold to Murari Saraf, Banwari Lal Saraf and Bihari Lal Saraf respectively by appellant No. 1, and whether consideration paid - If established appellant No. 1 divested rights before 09.04.1997 and respondents paid consideration, impugned order to follow - Appeal disposed by way of remand.
Transfer of 7000 equity shares - prohibitory order u/s 45MB (2) of RBI Act - Admitted possession of 4000 shares certificates and transfer deeds by Anoop Jain - Issue of consideration for 4000 shares - Anoop Jain relied on Delhi stock exchange register for payment of consideration - Appellants objected discrepancy in timeline of sale by appellant No. 1 and purchase by respondents, lack of proof of consideration payment - Matter remanded to Company Court to inquire when 4000 shares sold to Anoop Jain, 1500, 900 and 600 shares sold to Murari Saraf, Banwari Lal Saraf and Bihari Lal Saraf respectively by appellant No. 1, and whether consideration paid - If established appellant No. 1 divested rights before 09.04.1997 and respondents paid consideration, impugned order to follow - Appeal disposed by way of remand.
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