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...
Bail in GST prosecutions involving alleged fraudulent input tax credit depends on whether detention is necessary to secure trial attendance or prevent interference with justice. Criminal antecedents alone do not justify refusal without material indicating a risk of absconding, witness intimidation, evidence tampering, repetition of offences, or other obstruction. Pre-trial detention is not punitive, particularly where investigation is complete, the prosecution rests on documentary evidence, and trial may be delayed. The offence being triable by a Magistrate and carrying limited maximum punishment, together with the absence of assessment proceedings that could affect the alleged contravention, supported release on conditions protecting the trial and prosecution evidence.
Bail in GST prosecutions involving alleged fraudulent input tax credit depends on whether detention is necessary to secure trial attendance or prevent interference with justice. Criminal antecedents alone do not justify refusal without material indicating a risk of absconding, witness intimidation, evidence tampering, repetition of offences, or other obstruction. Pre-trial detention is not punitive, particularly where investigation is complete, the prosecution rests on documentary evidence, and trial may be delayed. The offence being triable by a Magistrate and carrying limited maximum punishment, together with the absence of assessment proceedings that could affect the alleged contravention, supported release on conditions protecting the trial and prosecution evidence.
Note: It is a system-generated summary and is for quick reference only.
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