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...
Territorial jurisdiction under Article 226 depends on whether the material, essential and integral cause of action arises within the forum, and the doctrine of forum conveniens may justify refusal even if some connection with Delhi exists. The Court held that the petitioners' residence, the searches and seizures, the ECIR, the investigating officers, and the PMLA proceedings were all centred in Gurugram, so Delhi was not the appropriate forum. It further held that the respondent-authority's location or the mere registration of the predicate offence in Delhi did not confer jurisdiction, because money-laundering is an independent offence. The writ petition was dismissed, with liberty to approach the jurisdictional High Court.
Territorial jurisdiction under Article 226 depends on whether the material, essential and integral cause of action arises within the forum, and the doctrine of forum conveniens may justify refusal even if some connection with Delhi exists. The Court held that the petitioners' residence, the searches and seizures, the ECIR, the investigating officers, and the PMLA proceedings were all centred in Gurugram, so Delhi was not the appropriate forum. It further held that the respondent-authority's location or the mere registration of the predicate offence in Delhi did not confer jurisdiction, because money-laundering is an independent offence. The writ petition was dismissed, with liberty to approach the jurisdictional High Court.
Note: It is a system-generated summary and is for quick reference only.