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 Tribunal discussed PMLA attachment where the money trail showed circulation of funds through group companies, paper entities and restructuring arrangements, and held that such routing could constitute layering and proceeds of crime. It rejected explanations based on surplus funds, security deposits, home loans or corporate debt restructuring when unsupported by records, and noted that the burden to disprove taint lay on the claimant. It also accepted equivalent value attachment where diverted funds were no longer available and sustained provisional attachment of properties, subject to the final outcome of trial.
The Tribunal discussed PMLA attachment where the money trail showed circulation of funds through group companies, paper entities and restructuring arrangements, and held that such routing could constitute layering and proceeds of crime. It rejected explanations based on surplus funds, security deposits, home loans or corporate debt restructuring when unsupported by records, and noted that the burden to disprove taint lay on the claimant. It also accepted equivalent value attachment where diverted funds were no longer available and sustained provisional attachment of properties, subject to the final outcome of trial.
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