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...
Absence of pre-trade authorisation is not conclusive of unauthorised trading and, by itself, may only trigger regulatory consequences; a client who does not object within a reasonable time cannot ordinarily disown the trades. Here, however, the HC upheld the arbitral award because the arbitrator found, on WhatsApp messages, audio recordings and transaction data, that the trades were manipulated, induced by promises of high returns, and continued under pressure, amounting to blatantly unauthorised and prejudicial trading. The Court also held that the broker was vicariously liable for fraudulent acts carried out by its Alliance Partner and employees in the course of the broker's business, so no patent illegality or perversity justified interference under Section 37.
Absence of pre-trade authorisation is not conclusive of unauthorised trading and, by itself, may only trigger regulatory consequences; a client who does not object within a reasonable time cannot ordinarily disown the trades. Here, however, the HC upheld the arbitral award because the arbitrator found, on WhatsApp messages, audio recordings and transaction data, that the trades were manipulated, induced by promises of high returns, and continued under pressure, amounting to blatantly unauthorised and prejudicial trading. The Court also held that the broker was vicariously liable for fraudulent acts carried out by its Alliance Partner and employees in the course of the broker's business, so no patent illegality or perversity justified interference under Section 37.
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