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...
An ECIR under the PMLA is an internal departmental document with no statutory status, so its quashing is not ordinarily maintainable unless the predicate offence itself is quashed; the challenge here was also premature because the alleged overlap with an earlier ECIR was not established. A subsequent ECIR or parallel investigation is permissible where it concerns a larger conspiracy, additional offences, or different accused, and is not barred as a second FIR. Statements recorded under Section 50 of the PMLA were not invalidated because Article 20(3), Section 164 CrPC safeguards, and Miranda-type protections apply only once a person is an accused or formally arrested. Section 50 summons and Section 66(2) information-sharing were upheld as part of lawful investigation, and a private person can be proceeded against for corruption-linked offences.
An ECIR under the PMLA is an internal departmental document with no statutory status, so its quashing is not ordinarily maintainable unless the predicate offence itself is quashed; the challenge here was also premature because the alleged overlap with an earlier ECIR was not established. A subsequent ECIR or parallel investigation is permissible where it concerns a larger conspiracy, additional offences, or different accused, and is not barred as a second FIR. Statements recorded under Section 50 of the PMLA were not invalidated because Article 20(3), Section 164 CrPC safeguards, and Miranda-type protections apply only once a person is an accused or formally arrested. Section 50 summons and Section 66(2) information-sharing were upheld as part of lawful investigation, and a private person can be proceeded against for corruption-linked offences.
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