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...
Attachment of property held by a person not accused of money laundering requires proof that proceeds of crime reached that person and funded acquisition of the property, or that the property constitutes equivalent-value property of a person involved in laundering. Alleged control of the purchasing company by an accused, based mainly on witness statements, does not replace evidence of a money trail. Bank-financed acquisition and the company's own savings were not shown to be proceeds of crime, layered proceeds, or assets belonging to the accused. The provisional attachment and its confirmation were therefore set aside.
Attachment of property held by a person not accused of money laundering requires proof that proceeds of crime reached that person and funded acquisition of the property, or that the property constitutes equivalent-value property of a person involved in laundering. Alleged control of the purchasing company by an accused, based mainly on witness statements, does not replace evidence of a money trail. Bank-financed acquisition and the company's own savings were not shown to be proceeds of crime, layered proceeds, or assets belonging to the accused. The provisional attachment and its confirmation were therefore set aside.
Note: It is a system-generated summary and is for quick reference only.
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