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...
Proceeds of crime and legality of petitioner's arrest under PMLA for alleged illegal mining were examined. Grounds of arrest and reasons to believe were based solely on purported illegal mining by fabricating e-rawana bills. In first eight FIRs, petitioner was not an accused. In ninth FIR too, petitioner was not named, but ED tried implicating him as Director of DSPL, which records showed he ceased being from 07.11.2013. ED failed to substantiate petitioner's involvement as Director, Promoter or shareholder of the alleged GM Co. No material showed petitioner directly or indirectly indulged in any process connected with proceeds of crime or projected untainted proceeds. No grounds for arrest under PMLA were made out against petitioner for money laundering offence. Petitioner not being involved in any illegal activity attracting PMLA offence, petition was allowed for his release if not required in any other case.
Proceeds of crime and legality of petitioner's arrest under PMLA for alleged illegal mining were examined. Grounds of arrest and reasons to believe were based solely on purported illegal mining by fabricating e-rawana bills. In first eight FIRs, petitioner was not an accused. In ninth FIR too, petitioner was not named, but ED tried implicating him as Director of DSPL, which records showed he ceased being from 07.11.2013. ED failed to substantiate petitioner's involvement as Director, Promoter or shareholder of the alleged GM Co. No material showed petitioner directly or indirectly indulged in any process connected with proceeds of crime or projected untainted proceeds. No grounds for arrest under PMLA were made out against petitioner for money laundering offence. Petitioner not being involved in any illegal activity attracting PMLA offence, petition was allowed for his release if not required in any other case.
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