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...
Successive bail applications require a substantial change in facts or circumstances directly affecting the merits; parity with a co-accused alone does not justify release because the court must assess the accused's individual role, the gravity of the allegations and the investigation material. Economic offences are treated as a distinct class for bail and attract a stricter approach because they may involve deliberate conspiracies and broader financial harm. On the stated facts, the accused was prima facie linked to fictitious firms, fake invoices, e-way bills and alleged GST evasion through documentary, electronic and recorded statement material, so later bail to a co-accused did not amount to a sufficient change in circumstances.
Successive bail applications require a substantial change in facts or circumstances directly affecting the merits; parity with a co-accused alone does not justify release because the court must assess the accused's individual role, the gravity of the allegations and the investigation material. Economic offences are treated as a distinct class for bail and attract a stricter approach because they may involve deliberate conspiracies and broader financial harm. On the stated facts, the accused was prima facie linked to fictitious firms, fake invoices, e-way bills and alleged GST evasion through documentary, electronic and recorded statement material, so later bail to a co-accused did not amount to a sufficient change in circumstances.
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