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 appeals under PMLA were allowed. The freezing/attachment order would continue during the investigation period of 365 days or pendency of the case before the Court concerning offenses under the Act of 2002. However, after the expiry of over 2 years since the freezing order without a prosecution complaint filed against any accused, the impugned order lapsed due to the efflux of time. Consequently, the Appellate Tribunal set aside the impugned order declaring the freezing order and its confirmation to have lapsed in the absence of a prosecution complaint against any accused.
The appeals under PMLA were allowed. The freezing/attachment order would continue during the investigation period of 365 days or pendency of the case before the Court concerning offenses under the Act of 2002. However, after the expiry of over 2 years since the freezing order without a prosecution complaint filed against any accused, the impugned order lapsed due to the efflux of time. Consequently, the Appellate Tribunal set aside the impugned order declaring the freezing order and its confirmation to have lapsed in the absence of a prosecution complaint against any accused.
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