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...
Grant of Regular Bail - Forged tax invoices - Non-existent ghost business entities - commission of offence u/s 132(1)(b)(c) & (l) of the OGST Act - The court acknowledged the severe impact of economic offenses but also reiterated the fundamental right to personal liberty as enshrined in the Constitution. The court noted that the trial was well underway with significant witness testimonies already on record, reducing the risk of evidence tampering. The accused had already been in custody for a considerable period, which the court viewed as potentially punitive and prejudicial to the rights of the accused. Ultimately, the court granted bail to the applicants, setting stringent financial conditions and imposing strict requirements to ensure their appearance at trial.
Grant of Regular Bail - Forged tax invoices - Non-existent ghost business entities - commission of offence u/s 132(1)(b)(c) & (l) of the OGST Act - The court acknowledged the severe impact of economic offenses but also reiterated the fundamental right to personal liberty as enshrined in the Constitution. The court noted that the trial was well underway with significant witness testimonies already on record, reducing the risk of evidence tampering. The accused had already been in custody for a considerable period, which the court viewed as potentially punitive and prejudicial to the rights of the accused. Ultimately, the court granted bail to the applicants, setting stringent financial conditions and imposing strict requirements to ensure their appearance at trial.
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