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 u/s 437 - tax evasion - The court examined the charges against the accused and found that they were detained for alleged offenses under the CGST Act. However, it emphasized the necessity for clear communication of charges in the arrest memo, as directed by legal precedents. - The court acknowledged procedural irregularities but noted that the accused had been in custody since their arrest. It highlighted the accused's cooperation with the investigation and concluded that there was no need for further detention. - Bail granted subject to conditions.
Seeking grant of Bail u/s 437 - tax evasion - The court examined the charges against the accused and found that they were detained for alleged offenses under the CGST Act. However, it emphasized the necessity for clear communication of charges in the arrest memo, as directed by legal precedents. - The court acknowledged procedural irregularities but noted that the accused had been in custody since their arrest. It highlighted the accused's cooperation with the investigation and concluded that there was no need for further detention. - Bail granted subject to conditions.
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