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...
Tribunal affirmed that issuance of duplicate share certificates without informing the registered shareholder breached the company's duty and violated due diligence obligations of the registrar/transfer agent; consequence: register must be rectified and shares restored to the original shareholder. Tribunal found negligent conduct in issuing duplicates and simultaneous transfer to an impostor, warranting compensation as alternative relief; consequence: damages equivalent to market value of the shares were ordered where restoration failed. Tribunal also awarded litigation costs to compensate the aggrieved individual for legal expenses. Appeal against the rectification and alternative compensation was dismissed.
Tribunal affirmed that issuance of duplicate share certificates without informing the registered shareholder breached the company's duty and violated due diligence obligations of the registrar/transfer agent; consequence: register must be rectified and shares restored to the original shareholder. Tribunal found negligent conduct in issuing duplicates and simultaneous transfer to an impostor, warranting compensation as alternative relief; consequence: damages equivalent to market value of the shares were ordered where restoration failed. Tribunal also awarded litigation costs to compensate the aggrieved individual for legal expenses. Appeal against the rectification and alternative compensation was dismissed.
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