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...
Properties acquired before the scheduled offence could still be attached as value of proceeds of crime where tainted funds were used to repay loans or the direct proceeds were unavailable; disclosure of the assets in income-tax records did not alter the alleged tainted character of the funds. The Tribunal also held that statements recorded under Section 50 of PMLA are admissible in proceedings under the Act and may be relied on even if later disputed, where supporting material exists. However, provisional attachment of a security deposit already in Judicial Magistrate custody failed because reasons to believe under Section 5(1) must include a real apprehension of concealment, transfer, or frustration of confiscation; that attachment was set aside.
Properties acquired before the scheduled offence could still be attached as value of proceeds of crime where tainted funds were used to repay loans or the direct proceeds were unavailable; disclosure of the assets in income-tax records did not alter the alleged tainted character of the funds. The Tribunal also held that statements recorded under Section 50 of PMLA are admissible in proceedings under the Act and may be relied on even if later disputed, where supporting material exists. However, provisional attachment of a security deposit already in Judicial Magistrate custody failed because reasons to believe under Section 5(1) must include a real apprehension of concealment, transfer, or frustration of confiscation; that attachment was set aside.
Note: It is a system-generated summary and is for quick reference only.