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 crux of the matter revolves around allegations of oppression, mismanagement, illegal sale of company land, allotment of equity shares, appointment and removal of directors, and the legality of extraordinary general meetings and resolutions. The key findings are: the sale of land parcels at a lower price, though below market value, does not constitute oppression or mismanagement as the company urgently required funds, and the petitioner had consented to the sale price. The lease deed with Padmavatahi Ispat, though signed, was never executed and subsequently cancelled, hence not amounting to oppression. The allotment of 17,29,000 equity shares to respondents is held to be legal and valid. The acts of respondents are not prejudicial or oppressive to petitioners, nor are the company's affairs conducted prejudicially. Consequently, the petition lacks merit and is dismissed by the Tribunal.
The crux of the matter revolves around allegations of oppression, mismanagement, illegal sale of company land, allotment of equity shares, appointment and removal of directors, and the legality of extraordinary general meetings and resolutions. The key findings are: the sale of land parcels at a lower price, though below market value, does not constitute oppression or mismanagement as the company urgently required funds, and the petitioner had consented to the sale price. The lease deed with Padmavatahi Ispat, though signed, was never executed and subsequently cancelled, hence not amounting to oppression. The allotment of 17,29,000 equity shares to respondents is held to be legal and valid. The acts of respondents are not prejudicial or oppressive to petitioners, nor are the company's affairs conducted prejudicially. Consequently, the petition lacks merit and is dismissed by the Tribunal.
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