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...
Beneficial ownership was sufficient to sustain proceedings under sections 241-242 and 59 where the transferee had paid full consideration, the sale was confirmed in foreign liquidation, and the liquidator had acknowledged that legal and financial interest in the shares had vested in it; the company could not rely on its own failure to complete transfer formalities to deny locus. The EOGM notice was held valid because it was sent to the liquidator's official email address and there was no legal requirement to send it separately to the secretary. Share transfer under the articles was also held to carry the transferor's obligations, including the non-compete covenant, and the transferee was directed to be admitted as shareholder subject to that covenant.
Beneficial ownership was sufficient to sustain proceedings under sections 241-242 and 59 where the transferee had paid full consideration, the sale was confirmed in foreign liquidation, and the liquidator had acknowledged that legal and financial interest in the shares had vested in it; the company could not rely on its own failure to complete transfer formalities to deny locus. The EOGM notice was held valid because it was sent to the liquidator's official email address and there was no legal requirement to send it separately to the secretary. Share transfer under the articles was also held to carry the transferor's obligations, including the non-compete covenant, and the transferee was directed to be admitted as shareholder subject to that covenant.
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