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...
Quashment was refused where allegations of large-scale illegal mining, criminal conspiracy and connected PMLA laundering disclosed a prima facie case; disputed issues on valuation, quarried quantity, competing committee reports and the exact loss to the State were held to be matters for trial, not for threshold interference. The later committee report, prepared for damage assessment and not accepted for criminal liability, did not by itself end either the predicate offences or the PMLA complaint. Statements under Section 161 CrPC, claims of tutoring and the women partners' later retirement from the firm were also treated as trial issues, and the prosecution was allowed to continue.
Quashment was refused where allegations of large-scale illegal mining, criminal conspiracy and connected PMLA laundering disclosed a prima facie case; disputed issues on valuation, quarried quantity, competing committee reports and the exact loss to the State were held to be matters for trial, not for threshold interference. The later committee report, prepared for damage assessment and not accepted for criminal liability, did not by itself end either the predicate offences or the PMLA complaint. Statements under Section 161 CrPC, claims of tutoring and the women partners' later retirement from the firm were also treated as trial issues, and the prosecution was allowed to continue.
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