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 encompass any property derived from criminal activity related to scheduled offenses, including property held abroad equivalent to domestic assets. Companies can be prosecuted for money laundering offenses irrespective of individuals' prosecution u/s 70 of PMLA. Provisional attachment orders need not be adjudicated in petitions filed u/s 482 CrPC. Prima facie case established for prosecuting individuals and companies under PMLA. Petitioners must establish defense based on merits and evidence. Petition dismissed.
Proceeds of crime encompass any property derived from criminal activity related to scheduled offenses, including property held abroad equivalent to domestic assets. Companies can be prosecuted for money laundering offenses irrespective of individuals' prosecution u/s 70 of PMLA. Provisional attachment orders need not be adjudicated in petitions filed u/s 482 CrPC. Prima facie case established for prosecuting individuals and companies under PMLA. Petitioners must establish defense based on merits and evidence. Petition dismissed.
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