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...
Interim access to frozen funds under the PMLA may be permitted for essential employee salaries and statutory dues where the liabilities are genuine, the subsidiary prima facie owes funds to its holding company, and safeguards preserve the attached assets. Verified payments of TDS and GST avoid compelled statutory defaults while benefiting the Central Government. Limited access was permitted for verified outstanding salaries and statutory dues, subject to submission of payment details, verification and bank-authorisation safeguards, without addressing the merits of the pending appeals.
Interim access to frozen funds under the PMLA may be permitted for essential employee salaries and statutory dues where the liabilities are genuine, the subsidiary prima facie owes funds to its holding company, and safeguards preserve the attached assets. Verified payments of TDS and GST avoid compelled statutory defaults while benefiting the Central Government. Limited access was permitted for verified outstanding salaries and statutory dues, subject to submission of payment details, verification and bank-authorisation safeguards, without addressing the merits of the pending appeals.
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