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...
In an economic-offence investigation, the HC treated a seven-day prior notice requirement before coercive action as a limited safeguard, not anticipatory bail or blanket protection from arrest. Because the matter was still at the summons stage and no proposal for prior approval to arrest had been moved, the Court held that investigation could continue and the respondents had to join as called. The Department remained free to proceed in accordance with law if they did not cooperate. The challenge to the notice direction failed and the petitions were dismissed.
In an economic-offence investigation, the HC treated a seven-day prior notice requirement before coercive action as a limited safeguard, not anticipatory bail or blanket protection from arrest. Because the matter was still at the summons stage and no proposal for prior approval to arrest had been moved, the Court held that investigation could continue and the respondents had to join as called. The Department remained free to proceed in accordance with law if they did not cooperate. The challenge to the notice direction failed and the petitions were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
