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...
The Supreme Court held that amounts repayable after a specified period, with promised quarterly interest, fell within the wide definition of "deposit" under Section 2(c) of the MPID Act. It further held that Section 2(d) uses expansive language and includes private persons receiving such deposits, so respondent Nos. 2 to 6 were financial establishments for MPID Act purposes. Prior failure of IPC-based proceedings and the civil character of the transaction did not bar recourse under Section 3, because the MPID Act provides an independent statutory remedy operating in a distinct field. The High Court's contrary view was set aside.
The Supreme Court held that amounts repayable after a specified period, with promised quarterly interest, fell within the wide definition of "deposit" under Section 2(c) of the MPID Act. It further held that Section 2(d) uses expansive language and includes private persons receiving such deposits, so respondent Nos. 2 to 6 were financial establishments for MPID Act purposes. Prior failure of IPC-based proceedings and the civil character of the transaction did not bar recourse under Section 3, because the MPID Act provides an independent statutory remedy operating in a distinct field. The High Court's contrary view was set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
