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...
SC upheld the jurisdictional bar under Section 69(1) of the Indian Partnership Act, 1932, rendering the suit by partners of an unregistered partnership firm for money recovery non-maintainable. The Court conclusively determined that since the partnership firm was unregistered, the plaintiffs were legally precluded from filing a suit against another partner for monetary recovery. The High Court's order was affirmed, and the Special Leave Petition was dismissed, establishing that an unregistered partnership firm cannot pursue such legal proceedings without first registering the partnership.
SC upheld the jurisdictional bar under Section 69(1) of the Indian Partnership Act, 1932, rendering the suit by partners of an unregistered partnership firm for money recovery non-maintainable. The Court conclusively determined that since the partnership firm was unregistered, the plaintiffs were legally precluded from filing a suit against another partner for monetary recovery. The High Court's order was affirmed, and the Special Leave Petition was dismissed, establishing that an unregistered partnership firm cannot pursue such legal proceedings without first registering the partnership.
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