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 HC dismissed a writ application challenging seizure of goods and vehicle due to fatal procedural defects in the supporting affidavit. The deponent, Gopal Yadav, failed to establish proper authorization to represent all petitioners, claiming only to be the manager-cum-authorized representative of petitioner no.3. The affidavit lacked mandatory declarations that the deponent had reviewed the statements in the application or had them explained to him. These deficiencies rendered the affidavit legally insufficient under Patna HC rules. Finding the writ application incompetent due to improper representation, the court dismissed it as withdrawn.
The HC dismissed a writ application challenging seizure of goods and vehicle due to fatal procedural defects in the supporting affidavit. The deponent, Gopal Yadav, failed to establish proper authorization to represent all petitioners, claiming only to be the manager-cum-authorized representative of petitioner no.3. The affidavit lacked mandatory declarations that the deponent had reviewed the statements in the application or had them explained to him. These deficiencies rendered the affidavit legally insufficient under Patna HC rules. Finding the writ application incompetent due to improper representation, the court dismissed it as withdrawn.
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