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...
At the attachment stage under PMLA, the Tribunal applied preponderance of probabilities and held that bank trail material, statements of the persons concerned, the cash book and RTGS/NEFT records were sufficient to show receipt of proceeds of crime by the appellant; minor discrepancies in the cash figures did not destroy the evidentiary value, and final culpability was left to the pending prosecution complaint. It also held that property acquired before the crime period remained liable to equivalent value attachment where direct proceeds were no longer available, since no bar flows from the definition of proceeds of crime. Attachment was treated as a protective measure, and the appeal was dismissed.
At the attachment stage under PMLA, the Tribunal applied preponderance of probabilities and held that bank trail material, statements of the persons concerned, the cash book and RTGS/NEFT records were sufficient to show receipt of proceeds of crime by the appellant; minor discrepancies in the cash figures did not destroy the evidentiary value, and final culpability was left to the pending prosecution complaint. It also held that property acquired before the crime period remained liable to equivalent value attachment where direct proceeds were no longer available, since no bar flows from the definition of proceeds of crime. Attachment was treated as a protective measure, and the appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
