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...
Validity of SEBI Settlement Proceedings Regulations, specifically Regulations 6(1)(f) and 13(2)(ba) of the SEBI (Settlement Proceedings) Regulations, 2018. It examines allegations against noticees of acting in concert while acquiring shares without required disclosures, creating false trading appearances, and manipulative trading practices. The court held that the allegations in the show cause notice, if proven, are grave. It observed that the petitioners' objective was to stall adjudication proceedings by filing settlement applications and refusing to cooperate. The court rejected arguments of excessive delegation and manifest arbitrariness in the Regulations, stating they conform to the parent Acts and do not lack logical consistency or determining principles. It upheld the rejection of the petitioners' settlement proposal, finding the conditions imposed reasonable considering the allegations. The court criticized attempts to stall proceedings through constitutional challenges and interim relief pleas, emphasizing a pragmatic approach balancing defaulters' and public interests.
Validity of SEBI Settlement Proceedings Regulations, specifically Regulations 6(1)(f) and 13(2)(ba) of the SEBI (Settlement Proceedings) Regulations, 2018. It examines allegations against noticees of acting in concert while acquiring shares without required disclosures, creating false trading appearances, and manipulative trading practices. The court held that the allegations in the show cause notice, if proven, are grave. It observed that the petitioners' objective was to stall adjudication proceedings by filing settlement applications and refusing to cooperate. The court rejected arguments of excessive delegation and manifest arbitrariness in the Regulations, stating they conform to the parent Acts and do not lack logical consistency or determining principles. It upheld the rejection of the petitioners' settlement proposal, finding the conditions imposed reasonable considering the allegations. The court criticized attempts to stall proceedings through constitutional challenges and interim relief pleas, emphasizing a pragmatic approach balancing defaulters' and public interests.
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