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...
Passport renewal may be granted for its regular ten-year term during pending criminal proceedings where prior court permission remains mandatory for foreign travel. Travel restrictions, reinforced by directions to investigating and immigration authorities, provide sufficient safeguards against unauthorised departure regardless of the passport's validity period. In the absence of plausible reasons, substantive harm, or reasonable apprehension, limiting renewal to three years was not justified, particularly given the accused's stated roots in India. Renewal for ten years operates subject to all continuing conditions requiring prior court approval before travel abroad.
Passport renewal may be granted for its regular ten-year term during pending criminal proceedings where prior court permission remains mandatory for foreign travel. Travel restrictions, reinforced by directions to investigating and immigration authorities, provide sufficient safeguards against unauthorised departure regardless of the passport's validity period. In the absence of plausible reasons, substantive harm, or reasonable apprehension, limiting renewal to three years was not justified, particularly given the accused's stated roots in India. Renewal for ten years operates subject to all continuing conditions requiring prior court approval before travel abroad.
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