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...
Prolonged pre-trial custody in money-laundering proceedings may require constitutional protection of personal liberty and speedy trial under Article 21 to prevail over the bail restrictions in Section 45 of the PMLA. No fixed custody period determines this result; the assessment depends on the alleged role, prescribed sentence, trial stage and expected duration, and risks of absconding or interference with evidence. Where investigation is complete, trial progress remains delayed, no early completion is realistic, and delay is not attributable to the accused, the statutory twin conditions may be diluted. Regular bail may then be granted subject to appropriate conditions.
Prolonged pre-trial custody in money-laundering proceedings may require constitutional protection of personal liberty and speedy trial under Article 21 to prevail over the bail restrictions in Section 45 of the PMLA. No fixed custody period determines this result; the assessment depends on the alleged role, prescribed sentence, trial stage and expected duration, and risks of absconding or interference with evidence. Where investigation is complete, trial progress remains delayed, no early completion is realistic, and delay is not attributable to the accused, the statutory twin conditions may be diluted. Regular bail may then be granted subject to appropriate conditions.
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