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...
Forensic audit expenses incurred in aid of the Asset Disposal Committee's asset-disposal functions were treated as incidental and therefore payable by the Committee, including the fees of the Chartered Accountant firm engaged for that purpose. The Court also directed the Union of India to frame a reimbursement mechanism if sale realisations ultimately fall short of the amounts raised through the scheme. In the investor restitution framework, the Court permitted SDMS to be engaged to ensure continuity and speed, ordered transfer of website credentials, digital records and updated application materials from WEBEL, and issued consequential directions for further action against assets not yet attached or not in the physical possession of the Enforcement Directorate.
Forensic audit expenses incurred in aid of the Asset Disposal Committee's asset-disposal functions were treated as incidental and therefore payable by the Committee, including the fees of the Chartered Accountant firm engaged for that purpose. The Court also directed the Union of India to frame a reimbursement mechanism if sale realisations ultimately fall short of the amounts raised through the scheme. In the investor restitution framework, the Court permitted SDMS to be engaged to ensure continuity and speed, ordered transfer of website credentials, digital records and updated application materials from WEBEL, and issued consequential directions for further action against assets not yet attached or not in the physical possession of the Enforcement Directorate.
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