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 - Evasion of GST - The High Court identified several deficiencies in the prosecution's case. Firstly, the absence of prior sanction from the Commissioner for prosecuting GST offenses undermined the validity of the charges. Additionally, discrepancies in the applicant's signature on official documents raised suspicions of forgery, casting doubt on the prosecution's claims. Furthermore, the inadequacy of evidence presented during the trial, highlighted by admissions from a prosecution witness, further weakened the case against the applicant. Consequently, the High Court allowed the applicant's bail application, emphasizing the lack of concrete evidence and procedural lapses in the prosecution's case.
Seeking grant of bail - Evasion of GST - The High Court identified several deficiencies in the prosecution's case. Firstly, the absence of prior sanction from the Commissioner for prosecuting GST offenses undermined the validity of the charges. Additionally, discrepancies in the applicant's signature on official documents raised suspicions of forgery, casting doubt on the prosecution's claims. Furthermore, the inadequacy of evidence presented during the trial, highlighted by admissions from a prosecution witness, further weakened the case against the applicant. Consequently, the High Court allowed the applicant's bail application, emphasizing the lack of concrete evidence and procedural lapses in the prosecution's case.
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