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...
In criminal complaints arising during pending tax proceedings, the earlier writ order had reserved the petitioner's liberty to raise all defences before the criminal court, including a request to await the outcome of the substantive tax case. After the assessment appeal was later disposed of, the High Court held that the Magistrate's rejection of the petitioner's applications could not stand. The impugned order was quashed, the applications were restored for fresh consideration, and all rival contentions, including on Section 223 of the Bharatiya Nagarik Suraksha Sanhita, 2023, were left open.
In criminal complaints arising during pending tax proceedings, the earlier writ order had reserved the petitioner's liberty to raise all defences before the criminal court, including a request to await the outcome of the substantive tax case. After the assessment appeal was later disposed of, the High Court held that the Magistrate's rejection of the petitioner's applications could not stand. The impugned order was quashed, the applications were restored for fresh consideration, and all rival contentions, including on Section 223 of the Bharatiya Nagarik Suraksha Sanhita, 2023, were left open.
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