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...
Clubbing alleged clandestine removal with undervaluation for GST arrest was held unsustainable because the court found no legal justification for treating the two allegations as the same offence, and noted that undervaluation required separate statutory determination; on that basis, the arrest and remand lost their foundation. It also found non-compliance with mandatory arrest safeguards, including failure to supply grounds of arrest in the prescribed manner, inadequate intimation to a relative or friend, omission of the place of arrest, and a mechanical remand order that ignored the accused's objections and the applicable law. The detention, arrest, remand and custody were therefore held illegal, and the proceedings were quashed with liberty to proceed afresh in accordance with law.
Clubbing alleged clandestine removal with undervaluation for GST arrest was held unsustainable because the court found no legal justification for treating the two allegations as the same offence, and noted that undervaluation required separate statutory determination; on that basis, the arrest and remand lost their foundation. It also found non-compliance with mandatory arrest safeguards, including failure to supply grounds of arrest in the prescribed manner, inadequate intimation to a relative or friend, omission of the place of arrest, and a mechanical remand order that ignored the accused's objections and the applicable law. The detention, arrest, remand and custody were therefore held illegal, and the proceedings were quashed with liberty to proceed afresh in accordance with law.
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