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...
NDPS bail for foreign nationals accused of offences involving commercial quantity remains subject to the statutory twin conditions, and incarceration alone does not displace them. Bail safeguards must protect Article 21 while reasonably securing attendance and preventing flight: passport deposit, FRRO registration, verified residence, disclosure of funds and bank accounts, embassy intimation, and ordinarily two genuine sureties may be required. Sureties must undergo pre-release scrutiny of identity, address and financial credentials; fabricated sureties may trigger departmental inquiry where officials failed to exercise reasonable care, and surety property may be subject to a lien or charge upon bond forfeiture. Interim Article 142 directions prescribe uniform safeguards pending action by competent authorities.
NDPS bail for foreign nationals accused of offences involving commercial quantity remains subject to the statutory twin conditions, and incarceration alone does not displace them. Bail safeguards must protect Article 21 while reasonably securing attendance and preventing flight: passport deposit, FRRO registration, verified residence, disclosure of funds and bank accounts, embassy intimation, and ordinarily two genuine sureties may be required. Sureties must undergo pre-release scrutiny of identity, address and financial credentials; fabricated sureties may trigger departmental inquiry where officials failed to exercise reasonable care, and surety property may be subject to a lien or charge upon bond forfeiture. Interim Article 142 directions prescribe uniform safeguards pending action by competent authorities.
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