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...
Money Laundering - Validity of framing of charges - dealing in skin and organs of prohibited animals - proceeds of crime - scheduled offence - The High court emphasizes that at the stage of framing charges, only a prima facie case needs to be established. It notes the dispute over the valuation of seized goods but concludes that such disputes should be addressed during the trial. Similarly, doubts about income tax returns are deemed insufficient grounds for discharge. Ultimately, the court finds that the prosecution's case establishes a prima facie basis for proceeding with the trial, dismissing the applicants' application.
Money Laundering - Validity of framing of charges - dealing in skin and organs of prohibited animals - proceeds of crime - scheduled offence - The High court emphasizes that at the stage of framing charges, only a prima facie case needs to be established. It notes the dispute over the valuation of seized goods but concludes that such disputes should be addressed during the trial. Similarly, doubts about income tax returns are deemed insufficient grounds for discharge. Ultimately, the court finds that the prosecution's case establishes a prima facie basis for proceeding with the trial, dismissing the applicants' application.
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