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 provisional attachment over PACL-linked properties could not be continued where the Supreme Court had already created a special Article 142 restitution framework for investors. The Court noted that enforcement powers are not extinguished by judicial directions, but they must operate consistently with the court-prescribed mechanism. It further held that restoration under the PMLA is only a limited exception dependent on Special Court satisfaction and cannot justify parallel continuation of attachment when the special process is available. Because the attachment had already served any preservative purpose and prolonged pendency was prejudicing investor interests, the matter was directed to proceed under the Supreme Court-created framework, and the attachment orders were set aside.
PMLA provisional attachment over PACL-linked properties could not be continued where the Supreme Court had already created a special Article 142 restitution framework for investors. The Court noted that enforcement powers are not extinguished by judicial directions, but they must operate consistently with the court-prescribed mechanism. It further held that restoration under the PMLA is only a limited exception dependent on Special Court satisfaction and cannot justify parallel continuation of attachment when the special process is available. Because the attachment had already served any preservative purpose and prolonged pendency was prejudicing investor interests, the matter was directed to proceed under the Supreme Court-created framework, and the attachment orders were set aside.
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