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 release of petitioner - Right to Sleep - The High Court found that the petitioner was not detained when he entered the Enforcement Directorate (ED) office under Section 50 summons of the PMLA. The arrest was deemed legal as per Section 19 of the PMLA, and the petitioner was produced before the Special Court within 24 hours. - While acknowledging the importance of the right to sleep, the Court noted that the petitioner's statement was recorded voluntarily, albeit at an inconvenient hour. The Court deprecated the practice of recording statements post-midnight and directed the ED to issue guidelines for the timing of statement recordings under Section 50 of the PMLA.
Seeking release of petitioner - Right to Sleep - The High Court found that the petitioner was not detained when he entered the Enforcement Directorate (ED) office under Section 50 summons of the PMLA. The arrest was deemed legal as per Section 19 of the PMLA, and the petitioner was produced before the Special Court within 24 hours. - While acknowledging the importance of the right to sleep, the Court noted that the petitioner's statement was recorded voluntarily, albeit at an inconvenient hour. The Court deprecated the practice of recording statements post-midnight and directed the ED to issue guidelines for the timing of statement recordings under Section 50 of the PMLA.
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