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 complaint was time-barred and filed beyond the stipulated period u/s 142(b) of the NI Act. The demand notice was served to the accused company through email on 11.03.2022, which constituted effective service on the directors as well. The limitation period commenced from the date of service, and the complaint filed on 28.04.2022 was beyond the prescribed time limit without seeking condonation of delay. The trial court took cognizance without considering the delay, rendering the complaint not maintainable. Consequently, the criminal complaint was quashed, and the order taking cognizance was set aside by the High Court.
The complaint was time-barred and filed beyond the stipulated period u/s 142(b) of the NI Act. The demand notice was served to the accused company through email on 11.03.2022, which constituted effective service on the directors as well. The limitation period commenced from the date of service, and the complaint filed on 28.04.2022 was beyond the prescribed time limit without seeking condonation of delay. The trial court took cognizance without considering the delay, rendering the complaint not maintainable. Consequently, the criminal complaint was quashed, and the order taking cognizance was set aside by the High Court.
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