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...
A report under sections 206 to 208 of the Companies Act, 2013 must rest on a lawful inquiry or inspection, with the company first informed in writing of the allegations and given an opportunity to explain; here, no notices under section 206 were issued and the report itself showed that a fresh inspection was needed, so the report was ex facie illegal and was quashed. An SFIO investigation under section 212 requires material disclosing fraud, meaning conduct involving intent to deceive or gain undue advantage; persistent repayment defaults and related complaints, without more, did not establish fraud or a jurisdictional basis for SFIO action. The SFIO order, and the consequential summons and notices, were also quashed.
A report under sections 206 to 208 of the Companies Act, 2013 must rest on a lawful inquiry or inspection, with the company first informed in writing of the allegations and given an opportunity to explain; here, no notices under section 206 were issued and the report itself showed that a fresh inspection was needed, so the report was ex facie illegal and was quashed. An SFIO investigation under section 212 requires material disclosing fraud, meaning conduct involving intent to deceive or gain undue advantage; persistent repayment defaults and related complaints, without more, did not establish fraud or a jurisdictional basis for SFIO action. The SFIO order, and the consequential summons and notices, were also quashed.
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