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 High Court dealt with a case involving money laundering through the sale of illegally printed lottery tickets. The court held that the Prevention of Money Laundering Act (PMLA) aims to protect the economic interests of the nation, and its implementation should align with this legislative intent. The court found prima facie evidence of offenses under the Indian Penal Code, including cheating, forgery, and criminal conspiracy, constituting predicate offenses for money laundering under the PMLA. The state investigating agency had initially registered the predicate offense, but later filed a closure report, which the court deemed suspicious and an attempt to bury the case on extraneous considerations. The High Court set aside the closure report and directed the state agency and the Enforcement Directorate to proceed with the case in tandem, ensuring a fair trial uninfluenced by the court's observations.
The High Court dealt with a case involving money laundering through the sale of illegally printed lottery tickets. The court held that the Prevention of Money Laundering Act (PMLA) aims to protect the economic interests of the nation, and its implementation should align with this legislative intent. The court found prima facie evidence of offenses under the Indian Penal Code, including cheating, forgery, and criminal conspiracy, constituting predicate offenses for money laundering under the PMLA. The state investigating agency had initially registered the predicate offense, but later filed a closure report, which the court deemed suspicious and an attempt to bury the case on extraneous considerations. The High Court set aside the closure report and directed the state agency and the Enforcement Directorate to proceed with the case in tandem, ensuring a fair trial uninfluenced by the court's observations.
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