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 AT upheld FMC's jurisdiction to conduct inquiry into affairs of NMCE and its key management personnel to protect investors' interests. It found payment of Rs. 28.8 crore by NMCE to ATSPL for software development bogus, amounting to embezzlement. Allotment of NMCE shares to appellant No. 2 without following due process was held illegal. Appointment of 144 consultants without due diligence and misappropriation of NMCE funds of over Rs. 60 lakh for personal expenses by appellant No. 1 and family were also upheld as irregularities. The appeals were dismissed.
The AT upheld FMC's jurisdiction to conduct inquiry into affairs of NMCE and its key management personnel to protect investors' interests. It found payment of Rs. 28.8 crore by NMCE to ATSPL for software development bogus, amounting to embezzlement. Allotment of NMCE shares to appellant No. 2 without following due process was held illegal. Appointment of 144 consultants without due diligence and misappropriation of NMCE funds of over Rs. 60 lakh for personal expenses by appellant No. 1 and family were also upheld as irregularities. The appeals were dismissed.
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