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...
Arrest of professional working as tax consultant - repeated summons - in a case where the very basis leading to arrest on 23.03.2022 has not been challenged by the Petitioner, the Court is precluded to hold that the Corpus- Respondent No. 6 has been illegally detained merely because repeated summons were issued. - the date of petition of habeas corpus and the date of his production after his arrest being 23.03.2022, admittedly, if any prejudice could have been caused to the Corpus the substantive remedy was available and could have been resorted to. - the petition filed under Article 226 of the Constitution of India seeking a writ of habeas corpus need not be entertained in the facts and circumstances of the case. - HC
Arrest of professional working as tax consultant - repeated summons - in a case where the very basis leading to arrest on 23.03.2022 has not been challenged by the Petitioner, the Court is precluded to hold that the Corpus- Respondent No. 6 has been illegally detained merely because repeated summons were issued. - the date of petition of habeas corpus and the date of his production after his arrest being 23.03.2022, admittedly, if any prejudice could have been caused to the Corpus the substantive remedy was available and could have been resorted to. - the petition filed under Article 226 of the Constitution of India seeking a writ of habeas corpus need not be entertained in the facts and circumstances of the case. - HC
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