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...
Seeking grant of bail - Conspiracy - Illegal and fraudulent availment of fake Input Tax Credit - It is pertinent to observe that Section 70 of CGST Act provides for recording of statements with regard to the proceedings under the Act. This section nowhere specifically says that such statements can be used against the maker of such statements during the trial. The complainant has not pointed out any legal provision which makes it impossible for the maker of the statement under Section 70 of CGST Act to retract the same - The complainant department has not given any specific reason why the accused was not summoned after 22.06.2022. - Bail allowed - DSC
Seeking grant of bail - Conspiracy - Illegal and fraudulent availment of fake Input Tax Credit - It is pertinent to observe that Section 70 of CGST Act provides for recording of statements with regard to the proceedings under the Act. This section nowhere specifically says that such statements can be used against the maker of such statements during the trial. The complainant has not pointed out any legal provision which makes it impossible for the maker of the statement under Section 70 of CGST Act to retract the same - The complainant department has not given any specific reason why the accused was not summoned after 22.06.2022. - Bail allowed - DSC
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