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...
Writ petitions challenging arrests under PMLA were stated to be maintainable because they questioned the legality of deprivation of liberty, not the merits of the ECIR or bail. On the merits, the text says the arrests were unlawful because the Directorate relied on substantially the same earlier material and recycled allegations, without fresh tangible material to support the statutory reason to believe required for arrest. It also notes that arrest is not the first step in PMLA investigation: the summons power should be used first, yet no summons was issued or cooperation sought before arrest. The petitioners were directed to be released, while further action in accordance with law, including summons, remained open.
Writ petitions challenging arrests under PMLA were stated to be maintainable because they questioned the legality of deprivation of liberty, not the merits of the ECIR or bail. On the merits, the text says the arrests were unlawful because the Directorate relied on substantially the same earlier material and recycled allegations, without fresh tangible material to support the statutory reason to believe required for arrest. It also notes that arrest is not the first step in PMLA investigation: the summons power should be used first, yet no summons was issued or cooperation sought before arrest. The petitioners were directed to be released, while further action in accordance with law, including summons, remained open.
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