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 held that the petitioner bank should avail the alternate remedy of appeal u/s 15-T of the SEBI Act against SEBI's order dated January 11, 2023, instead of challenging SEBI's private communications expressing opinion on a legal provision through a writ petition. The Court granted liberty to the petitioner to file an appeal before the Securities Appellate Tribunal (SAT) within four weeks, and directed the SAT to dispose of the appeal on merits without considering the limitation issue. All contentions of parties on merits were left open to be decided by the SAT.
The High Court held that the petitioner bank should avail the alternate remedy of appeal u/s 15-T of the SEBI Act against SEBI's order dated January 11, 2023, instead of challenging SEBI's private communications expressing opinion on a legal provision through a writ petition. The Court granted liberty to the petitioner to file an appeal before the Securities Appellate Tribunal (SAT) within four weeks, and directed the SAT to dispose of the appeal on merits without considering the limitation issue. All contentions of parties on merits were left open to be decided by the SAT.
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