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 - Grant of bail - The petitioner, seeking bail after 14 months of detention, faced allegations of involvement in a complex money laundering scheme, using dummy firms and fraudulent accounts to launder substantial sums of money. The petitioner’s role extended beyond professional duties, involving active participation in the financial crimes. The court recognized the petitioner’s right to a fair trial under Article 21 but emphasized the gravity of the offenses and the ongoing investigation. The court applied the twin conditions under Section 45 of the PMLA, noting the failure of the petitioner to prove prima facie innocence. The court justified the continued detention, considering the seriousness of the economic offenses and the need for further investigation. Thus, the court rejected the bail application.
Money Laundering - Grant of bail - The petitioner, seeking bail after 14 months of detention, faced allegations of involvement in a complex money laundering scheme, using dummy firms and fraudulent accounts to launder substantial sums of money. The petitioner’s role extended beyond professional duties, involving active participation in the financial crimes. The court recognized the petitioner’s right to a fair trial under Article 21 but emphasized the gravity of the offenses and the ongoing investigation. The court applied the twin conditions under Section 45 of the PMLA, noting the failure of the petitioner to prove prima facie innocence. The court justified the continued detention, considering the seriousness of the economic offenses and the need for further investigation. Thus, the court rejected the bail application.
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