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...
Illness supported by undisputed medical material was treated as sufficient cause for condoning a 36-day delay in a petition under Section 58(3) of the Companies Act, with the Tribunal noting that the explanation remained uncontroverted despite opportunity. It held that "sufficient cause" is to be construed liberally to secure decision on merits, that Section 58(3) does not create a non-condonable outer limit, and that the Limitation Act principles could apply through Section 433 read with Section 29, with Rule 11 also available to advance substantial justice. The challenge to condonation was rejected and the delay remained condoned.
Illness supported by undisputed medical material was treated as sufficient cause for condoning a 36-day delay in a petition under Section 58(3) of the Companies Act, with the Tribunal noting that the explanation remained uncontroverted despite opportunity. It held that "sufficient cause" is to be construed liberally to secure decision on merits, that Section 58(3) does not create a non-condonable outer limit, and that the Limitation Act principles could apply through Section 433 read with Section 29, with Rule 11 also available to advance substantial justice. The challenge to condonation was rejected and the delay remained condoned.
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