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...
Petitioner sought regular bail, contending false implication and non-impleadment of main accused. Petitioner underwent 11 months and 26 days of custody, with another case pending on bail. Charges framed u/ss 420, 467, 468, 471 IPC and Section 132 CGST Act, 2017. Court observed that out of 12 prosecution witnesses, only 3 examined till date, and further detention would violate Article 21's right to speedy trial, as per Dataram Singh case. Deprivation of liberty without speedy trial inconsistent with Article 21, as per Abdul Rehman Antulay case. Veracity of allegations to be established during trial. Only 3 witnesses examined despite charges framed, rendering further incarceration purposeless. Without commenting on merits, bail granted subject to conditions, applying "bail is rule, jail exception" principle.
Petitioner sought regular bail, contending false implication and non-impleadment of main accused. Petitioner underwent 11 months and 26 days of custody, with another case pending on bail. Charges framed u/ss 420, 467, 468, 471 IPC and Section 132 CGST Act, 2017. Court observed that out of 12 prosecution witnesses, only 3 examined till date, and further detention would violate Article 21's right to speedy trial, as per Dataram Singh case. Deprivation of liberty without speedy trial inconsistent with Article 21, as per Abdul Rehman Antulay case. Veracity of allegations to be established during trial. Only 3 witnesses examined despite charges framed, rendering further incarceration purposeless. Without commenting on merits, bail granted subject to conditions, applying "bail is rule, jail exception" principle.
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