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 Tribunal upheld confirmation of provisional attachment under proceeds-of-crime law after finding a direct nexus between the properties and criminal activity. It held that the FIR was not exhaustive of the entire crime period and that investigation could validly establish a wider period from 2010 to 2020, rejecting the objection based on the narrower period initially stated in the FIR. The Tribunal also accepted statements showing that funds were provided by the mother for purchase of land and construction of flats, found no proof of an independent source, and treated unexplained cash deposits as further support for the attachment. The challenge to the source of acquisition therefore failed.
A Tribunal upheld confirmation of provisional attachment under proceeds-of-crime law after finding a direct nexus between the properties and criminal activity. It held that the FIR was not exhaustive of the entire crime period and that investigation could validly establish a wider period from 2010 to 2020, rejecting the objection based on the narrower period initially stated in the FIR. The Tribunal also accepted statements showing that funds were provided by the mother for purchase of land and construction of flats, found no proof of an independent source, and treated unexplained cash deposits as further support for the attachment. The challenge to the source of acquisition therefore failed.
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