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...
Alleged arrest irregularities did not support bail where the accused was produced before an available Magistrate after court hours and before the Special Court within twenty-four hours. Material showing that the written grounds of arrest were subsequently handed to relatives, together with prompt legal action on the accused's behalf, rebutted the claimed non-communication and showed no prejudice at the bail stage. Money-laundering bail remained unavailable despite prolonged custody because prima facie material linked the accused to providing mule accounts for illegal online betting, indicated a principal role, and raised risks of absconding, witness influence and evidence tampering. Proceedings had progressed towards framing of charges, and bail was refused.
Alleged arrest irregularities did not support bail where the accused was produced before an available Magistrate after court hours and before the Special Court within twenty-four hours. Material showing that the written grounds of arrest were subsequently handed to relatives, together with prompt legal action on the accused's behalf, rebutted the claimed non-communication and showed no prejudice at the bail stage. Money-laundering bail remained unavailable despite prolonged custody because prima facie material linked the accused to providing mule accounts for illegal online betting, indicated a principal role, and raised risks of absconding, witness influence and evidence tampering. Proceedings had progressed towards framing of charges, and bail was refused.
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