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...
Frozen funds alleged to be proceeds of crime could not be released under an interim arrangement to meet employee salaries and statutory dues of another company identified as the primary accused. The liabilities were not those of the company holding the frozen funds, and the asserted arrangement between the two companies did not justify their use. The interim direction permitting release was set aside, while the pending appeal before the Tribunal remained open for independent adjudication on its merits and was directed to be decided expeditiously.
Frozen funds alleged to be proceeds of crime could not be released under an interim arrangement to meet employee salaries and statutory dues of another company identified as the primary accused. The liabilities were not those of the company holding the frozen funds, and the asserted arrangement between the two companies did not justify their use. The interim direction permitting release was set aside, while the pending appeal before the Tribunal remained open for independent adjudication on its merits and was directed to be decided expeditiously.
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