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...
Issue estoppel applies in criminal proceedings where an earlier adjudication has distinctly raised or found the same issue, and parties are precluded from advancing legally inconsistent allegations; the court applied this principle to dismiss as barred a later complaint founded on the same letters and facts as an earlier complaint that was finally decided on merits as non-maintainable under company law. The earlier dismissal on merits operated as an estoppel against relitigation, and the subsequent complaint and related orders were quashed with the petition disposed of.
Issue estoppel applies in criminal proceedings where an earlier adjudication has distinctly raised or found the same issue, and parties are precluded from advancing legally inconsistent allegations; the court applied this principle to dismiss as barred a later complaint founded on the same letters and facts as an earlier complaint that was finally decided on merits as non-maintainable under company law. The earlier dismissal on merits operated as an estoppel against relitigation, and the subsequent complaint and related orders were quashed with the petition disposed of.
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