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...
The court granted bail to the accused applicant, considering the following factors: the trial has not yet commenced, the applicant's complicity is yet to be determined, relevant evidence is under the department's control, and there is no indication that the applicant's release would adversely affect the trial. Additionally, the alleged offense carries a maximum punishment of five years' imprisonment, and the applicant has already been in jail for a substantial period. The court opined that the applicant has made a case for bail, subject to furnishing personal bonds and sureties to the satisfaction of the concerned court and fulfilling imposed conditions. The decision was based on the Supreme Court's precedents, which emphasize considering the gravity of the offense, the object of the relevant Act, and the attending circumstances, rather than categorizing all economic offenses as one group and denying bail.
The court granted bail to the accused applicant, considering the following factors: the trial has not yet commenced, the applicant's complicity is yet to be determined, relevant evidence is under the department's control, and there is no indication that the applicant's release would adversely affect the trial. Additionally, the alleged offense carries a maximum punishment of five years' imprisonment, and the applicant has already been in jail for a substantial period. The court opined that the applicant has made a case for bail, subject to furnishing personal bonds and sureties to the satisfaction of the concerned court and fulfilling imposed conditions. The decision was based on the Supreme Court's precedents, which emphasize considering the gravity of the offense, the object of the relevant Act, and the attending circumstances, rather than categorizing all economic offenses as one group and denying bail.
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