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...
Provisional attachment of properties acquired from proceeds of crime may be sustained despite asserted prior sales, partial sales, or mortgages where recipients of funds from an accused entity cannot establish genuine business activity or an independent source for acquiring the properties. Properties traced to tainted funds through entities controlled by the accused remain subject to attachment. A person who has already sold a property has no subsisting interest to challenge its attachment; any purchaser may pursue an independent remedy. Mortgages do not by themselves require release of attached property, while any valid independent claim of a financial institution or other third party remains open.
Provisional attachment of properties acquired from proceeds of crime may be sustained despite asserted prior sales, partial sales, or mortgages where recipients of funds from an accused entity cannot establish genuine business activity or an independent source for acquiring the properties. Properties traced to tainted funds through entities controlled by the accused remain subject to attachment. A person who has already sold a property has no subsisting interest to challenge its attachment; any purchaser may pursue an independent remedy. Mortgages do not by themselves require release of attached property, while any valid independent claim of a financial institution or other third party remains open.
Note: It is a system-generated summary and is for quick reference only.
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