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...
HC upheld cancellation of petitioner's registration under Section 29(2)(e) due to fraudulent misrepresentation of business premises. Despite presenting electricity bills and leave/license agreement, petitioner failed to substantiate actual occupancy through proof of license fee payments or utility charges. Petitioner's inaction in responding to show cause notice, non-appearance before appellate authority, and failure to challenge Bureau of Investigation's spot visit findings proved detrimental. Court found proper officer's inference plausible based on available evidence. The registration cancellation order was deemed neither perverse nor unsupported by evidence, leading to dismissal of writ petition challenging the cancellation order.
HC upheld cancellation of petitioner's registration under Section 29(2)(e) due to fraudulent misrepresentation of business premises. Despite presenting electricity bills and leave/license agreement, petitioner failed to substantiate actual occupancy through proof of license fee payments or utility charges. Petitioner's inaction in responding to show cause notice, non-appearance before appellate authority, and failure to challenge Bureau of Investigation's spot visit findings proved detrimental. Court found proper officer's inference plausible based on available evidence. The registration cancellation order was deemed neither perverse nor unsupported by evidence, leading to dismissal of writ petition challenging the cancellation order.
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