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 in case involving sale/purchase of fake GST entities, issuance of fake firms and fraudulent beneficiaries of fake GST ITC. Considering attending circumstances, materials on record, law laid down in Ratnambar Kaushik and Satendra Kumar Antil cases, maximum punishment of up to 5 years, petitioner's custody for over 4 months, offence based on documentary evidence, investigation concluded, final P.R. submitted, HC persuaded to release petitioner on bail on stringent terms and conditions. Petitioner directed to be released on furnishing bail bond of Rs.50,000/- with two local solvent sureties each of like amount to satisfaction of court in seisin over matter and subject to fulfilment of conditions imposed. Bail application allowed.
Grant of regular bail in case involving sale/purchase of fake GST entities, issuance of fake firms and fraudulent beneficiaries of fake GST ITC. Considering attending circumstances, materials on record, law laid down in Ratnambar Kaushik and Satendra Kumar Antil cases, maximum punishment of up to 5 years, petitioner's custody for over 4 months, offence based on documentary evidence, investigation concluded, final P.R. submitted, HC persuaded to release petitioner on bail on stringent terms and conditions. Petitioner directed to be released on furnishing bail bond of Rs.50,000/- with two local solvent sureties each of like amount to satisfaction of court in seisin over matter and subject to fulfilment of conditions imposed. Bail application allowed.
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