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...
PMLA inquiry and civil action are described as not depending on prior registration of a predicate FIR or complaint: the ECIR is characterised as a non-statutory internal record, so quashing it is said to be misconceived, and summons under Section 50 are treated as part of the Act's inquiry and evidentiary machinery rather than prosecution. The text distinguishes the civil and penal limbs of the PMLA, stating that provisional attachment and related inquiry may proceed to secure proceeds of crime even where the scheduled offence FIR is not yet registered, with information to be shared under Section 66(2). It also states that income-tax settlement immunity does not bar independent PMLA proceedings; the appeal was dismissed.
PMLA inquiry and civil action are described as not depending on prior registration of a predicate FIR or complaint: the ECIR is characterised as a non-statutory internal record, so quashing it is said to be misconceived, and summons under Section 50 are treated as part of the Act's inquiry and evidentiary machinery rather than prosecution. The text distinguishes the civil and penal limbs of the PMLA, stating that provisional attachment and related inquiry may proceed to secure proceeds of crime even where the scheduled offence FIR is not yet registered, with information to be shared under Section 66(2). It also states that income-tax settlement immunity does not bar independent PMLA proceedings; the appeal was dismissed.
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