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 High Court quashed the criminal proceedings and cognizance orders against the petitioners for offenses u/ss 276B and 278B of the Income Tax Act. The TDS amount in question, which was the subject matter of the economic offense cases and C.O. Case, had already been deposited belatedly with interest to the Income Tax Department. The court held that continuing the proceedings would amount to an abuse of the process of law, given the deposit of the TDS amount and the amendment made to Section 276B in the Finance Act, 2024, allowing such delayed deposits. Consequently, the cognizance orders passed by the Special Judge, Economic Offenses, against the petitioners were quashed.
The High Court quashed the criminal proceedings and cognizance orders against the petitioners for offenses u/ss 276B and 278B of the Income Tax Act. The TDS amount in question, which was the subject matter of the economic offense cases and C.O. Case, had already been deposited belatedly with interest to the Income Tax Department. The court held that continuing the proceedings would amount to an abuse of the process of law, given the deposit of the TDS amount and the amendment made to Section 276B in the Finance Act, 2024, allowing such delayed deposits. Consequently, the cognizance orders passed by the Special Judge, Economic Offenses, against the petitioners were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
