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 - creation and operation of 294 fake firms and has evaded a tax - The court noted the serious nature of economic offences and the substantial loss to the public exchequer. It emphasized the need for a different approach in bail matters concerning economic crimes. - The court considered the rejection of bail for a co-accused in a similar case and upheld the decision, highlighting the substantial loss caused by the petitioner's actions. - Considering the evidence and seriousness of the offence, the court denied bail to the petitioner and instructed the trial court to expedite proceedings.
Seeking grant of bail - creation and operation of 294 fake firms and has evaded a tax - The court noted the serious nature of economic offences and the substantial loss to the public exchequer. It emphasized the need for a different approach in bail matters concerning economic crimes. - The court considered the rejection of bail for a co-accused in a similar case and upheld the decision, highlighting the substantial loss caused by the petitioner's actions. - Considering the evidence and seriousness of the offence, the court denied bail to the petitioner and instructed the trial court to expedite proceedings.
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