Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Company oppression/mismanagement petition amendments and maintainability after alleged share transfer and forgery claims; tribunal order quashed for l...
Invocation of the extended limitation proviso was examined on whether bona fide belief about Notification No.30/2012 and allocation of tax liability to service recipients supplied a plausible basis for non-payment; the analysis applied authorities requiring fraud, collusion, wilful misstatement or suppression of facts to invoke the extended five-year period. Absent documentary proof of transfer of possession or specific averments proving mala fide conduct or positive acts of suppression, mere non-payment or incomplete returns did not satisfy the threshold, and the extended-period demand was held unsustainable.
Invocation of the extended limitation proviso was examined on whether bona fide belief about Notification No.30/2012 and allocation of tax liability to service recipients supplied a plausible basis for non-payment; the analysis applied authorities requiring fraud, collusion, wilful misstatement or suppression of facts to invoke the extended five-year period. Absent documentary proof of transfer of possession or specific averments proving mala fide conduct or positive acts of suppression, mere non-payment or incomplete returns did not satisfy the threshold, and the extended-period demand was held unsustainable.
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