Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Financial irregularities found by SEBI rendered Acropetal Technologies Ltd.'s accounts and margins unreliable, so its exclusion from the comparables set was upheld for transfer pricing purposes. The Tribunal noted that diversion of funds to non-business use can materially distort operating margins and followed prior co-ordinate bench decisions excluding the same company. For intra-group support services, it accepted that a later APA margin could have persuasive value for a non-APA year where the transactions were identical, the FAR profile was unchanged, and documentary evidence supported receipt of services. The transfer pricing adjustment on support services was therefore deleted.
Financial irregularities found by SEBI rendered Acropetal Technologies Ltd.'s accounts and margins unreliable, so its exclusion from the comparables set was upheld for transfer pricing purposes. The Tribunal noted that diversion of funds to non-business use can materially distort operating margins and followed prior co-ordinate bench decisions excluding the same company. For intra-group support services, it accepted that a later APA margin could have persuasive value for a non-APA year where the transactions were identical, the FAR profile was unchanged, and documentary evidence supported receipt of services. The transfer pricing adjustment on support services was therefore deleted.
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