Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
The text addresses personal liability of directors in regulatory enforcement, holding that designation alone does not establish personal liability and that vicarious liability requires specific findings of individual involvement; this principle limits attachment of personal bank, demat and trading accounts absent substantive averments. It emphasises principles of natural justice and the limited scope of judicial review under Article 226 where regulatory findings entail factual appreciation, concluding that reasoned statutory orders invoking recovery and attachment powers under the SEBI Act warrant pursuit of the alternative statutory remedy before the Securities Appellate Tribunal rather than writ relief.
The text addresses personal liability of directors in regulatory enforcement, holding that designation alone does not establish personal liability and that vicarious liability requires specific findings of individual involvement; this principle limits attachment of personal bank, demat and trading accounts absent substantive averments. It emphasises principles of natural justice and the limited scope of judicial review under Article 226 where regulatory findings entail factual appreciation, concluding that reasoned statutory orders invoking recovery and attachment powers under the SEBI Act warrant pursuit of the alternative statutory remedy before the Securities Appellate Tribunal rather than writ relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
