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 petition filed u/s 213(b) of the Companies Act, 2013 alleged that the business of the respondent companies was being conducted with intent to defraud creditors, members, or others, or for fraudulent or unlawful purposes, or oppressively. However, the averments were not supported by material documents to substantiate such allegations. The documents filed failed to corroborate the allegations of fraudulent or unlawful conduct by the respondent company. The petitioner failed to make a prima facie case u/s 213(b). Consequently, the tribunal dismissed the petition in limine for lack of sufficient evidence to warrant appointing an inspector to investigate the respondent companies' affairs.
The petition filed u/s 213(b) of the Companies Act, 2013 alleged that the business of the respondent companies was being conducted with intent to defraud creditors, members, or others, or for fraudulent or unlawful purposes, or oppressively. However, the averments were not supported by material documents to substantiate such allegations. The documents filed failed to corroborate the allegations of fraudulent or unlawful conduct by the respondent company. The petitioner failed to make a prima facie case u/s 213(b). Consequently, the tribunal dismissed the petition in limine for lack of sufficient evidence to warrant appointing an inspector to investigate the respondent companies' affairs.
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