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...
Inter-agency information sharing under PMLA is permitted where the Director or authorised officer forms an opinion that another law has been contravened; the communication may properly be sent to the concerned agency for action. The text rejects the view that such disclosure is confined to PMLA offences or barred by FEMA powers, treating both statutes as cognate fields to be read together. It also states that, at the investigation stage, the court looks only for prima facie material: allegations of foreign-fund withdrawals linked to extremist activity were treated as sufficient to justify continued investigation, and the FIR was not to be quashed at the incipient stage.
Inter-agency information sharing under PMLA is permitted where the Director or authorised officer forms an opinion that another law has been contravened; the communication may properly be sent to the concerned agency for action. The text rejects the view that such disclosure is confined to PMLA offences or barred by FEMA powers, treating both statutes as cognate fields to be read together. It also states that, at the investigation stage, the court looks only for prima facie material: allegations of foreign-fund withdrawals linked to extremist activity were treated as sufficient to justify continued investigation, and the FIR was not to be quashed at the incipient stage.
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