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 later company petition was barred by res judicata where it sought substantially the same reliefs on the same cause of action as an earlier petition, including challenge to board resolutions, restoration of position in the company and control over bank operations. The Appellate Tribunal held that the earlier orders had attained finality because they were carried through the appellate process and left undisturbed, and withdrawal of the civil appeal before the Supreme Court did not permit reopening the concluded dispute. The fresh proceeding was therefore an abuse of process and the company appeal was dismissed.
A later company petition was barred by res judicata where it sought substantially the same reliefs on the same cause of action as an earlier petition, including challenge to board resolutions, restoration of position in the company and control over bank operations. The Appellate Tribunal held that the earlier orders had attained finality because they were carried through the appellate process and left undisturbed, and withdrawal of the civil appeal before the Supreme Court did not permit reopening the concluded dispute. The fresh proceeding was therefore an abuse of process and the company appeal was dismissed.
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