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...
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The court held that the gift deed executed by the defaulting brother in favor of the petitioner was a fraudulent attempt to obstruct the government from recovering legitimate dues. The timing of the gift deed, soon after the defaulter order, raised suspicion. The petitioner's conduct was questionable, including suppressing vital documents. The transaction appeared solely aimed at obstructing the sale of property to recover government dues. The court dismissed the petition with costs, stating that a petitioner with such conduct does not deserve extraordinary writ jurisdiction's assistance. The respondents were directed to initiate recovery proceedings against the petitioner for the defaulted dues.
The court held that the gift deed executed by the defaulting brother in favor of the petitioner was a fraudulent attempt to obstruct the government from recovering legitimate dues. The timing of the gift deed, soon after the defaulter order, raised suspicion. The petitioner's conduct was questionable, including suppressing vital documents. The transaction appeared solely aimed at obstructing the sale of property to recover government dues. The court dismissed the petition with costs, stating that a petitioner with such conduct does not deserve extraordinary writ jurisdiction's assistance. The respondents were directed to initiate recovery proceedings against the petitioner for the defaulted dues.
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