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...
Petitioner failed to produce the complete email extract confirming receipt of notices, creating a procedural irregularity that informed interim relief. The court required an interim deposit to secure the revenue interest because the effective promoter had left and the petitioner is represented by a senior citizen director; consequence is immediate: Rs. 25,00,000 must be deposited within 30 days by the petitioner (or her son as representative). Noncompliance permits respondents to treat the writ as dismissed and to take steps including extradition proceedings against the son. Writ petition disposed.
Petitioner failed to produce the complete email extract confirming receipt of notices, creating a procedural irregularity that informed interim relief. The court required an interim deposit to secure the revenue interest because the effective promoter had left and the petitioner is represented by a senior citizen director; consequence is immediate: Rs. 25,00,000 must be deposited within 30 days by the petitioner (or her son as representative). Noncompliance permits respondents to treat the writ as dismissed and to take steps including extradition proceedings against the son. Writ petition disposed.
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