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 appeal challenges the attachment order of gold and silver articles from lockers, questioning the identification of beneficial locker holders under the Prohibition of Benami Property Transactions Act. The court held that the conduct of the parties, particularly the Safe Vault Private Limited (SVPL), which failed to disclose the true ownership and delayed changing the name despite requests, speaks for itself. The SVPL's excuse of a bona fide mistake was unacceptable, and they were equally responsible for the benami transaction by not adhering to KYC norms. The appellant failed to disclose the source of acquisition of gold and silver, and the SVPL and appellant were hand in glove to mislead the respondent. The court found no violation of Section 24(1) of the Act, as notice was given to Shiv Daga, and the appellant had ample opportunity to present their case. Consequently, the appeal was dismissed.
The appeal challenges the attachment order of gold and silver articles from lockers, questioning the identification of beneficial locker holders under the Prohibition of Benami Property Transactions Act. The court held that the conduct of the parties, particularly the Safe Vault Private Limited (SVPL), which failed to disclose the true ownership and delayed changing the name despite requests, speaks for itself. The SVPL's excuse of a bona fide mistake was unacceptable, and they were equally responsible for the benami transaction by not adhering to KYC norms. The appellant failed to disclose the source of acquisition of gold and silver, and the SVPL and appellant were hand in glove to mislead the respondent. The court found no violation of Section 24(1) of the Act, as notice was given to Shiv Daga, and the appellant had ample opportunity to present their case. Consequently, the appeal was dismissed.
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