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 Commission perused the material and public domain information. The Informant alleged unfair and discriminatory interest rate hikes, frequent increases, and pre-payment penalties by OP-1, creating barriers for new entrants as consumers would be disinclined to switch due to potential losses. Conduct allegedly violated Sections 3(1), 3(2), and 4 of the Competition Act, 2002. The relevant market was delineated as 'provision of loan against property in India'. OP-1's dominance was not established due to the competitive presence of numerous banks, NBFCs, and housing finance companies. Allegations of aftermarket abuse were rejected as misplaced. No prima facie case was made out u/ss 3 and 4. The matter was closed u/s 26(2) as no competition concerns arose.
The Commission perused the material and public domain information. The Informant alleged unfair and discriminatory interest rate hikes, frequent increases, and pre-payment penalties by OP-1, creating barriers for new entrants as consumers would be disinclined to switch due to potential losses. Conduct allegedly violated Sections 3(1), 3(2), and 4 of the Competition Act, 2002. The relevant market was delineated as 'provision of loan against property in India'. OP-1's dominance was not established due to the competitive presence of numerous banks, NBFCs, and housing finance companies. Allegations of aftermarket abuse were rejected as misplaced. No prima facie case was made out u/ss 3 and 4. The matter was closed u/s 26(2) as no competition concerns arose.
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