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...
Approval for arrest under the CGST Act does not require final adjudication of tax liability; it is enough that recorded material creates a reason to believe that an offence under section 132 has been committed. The approving authority relied on employee and recipient statements, transporter data, CCTV footage, melting reports, tally data and seized records, so the arrest approval was not mechanical. In assessing bail, the accused's failure to answer summons, failure to produce promised particulars and retraction of an earlier statement led the court to find that he was unlikely to cooperate without custodial interrogation. Given the stage of investigation, alleged gravity and antecedents, bail was refused.
Approval for arrest under the CGST Act does not require final adjudication of tax liability; it is enough that recorded material creates a reason to believe that an offence under section 132 has been committed. The approving authority relied on employee and recipient statements, transporter data, CCTV footage, melting reports, tally data and seized records, so the arrest approval was not mechanical. In assessing bail, the accused's failure to answer summons, failure to produce promised particulars and retraction of an earlier statement led the court to find that he was unlikely to cooperate without custodial interrogation. Given the stage of investigation, alleged gravity and antecedents, bail was refused.
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