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 dismissed the petition challenging the complaint filed under the Prevention of Money Laundering Act (PMLA) for customs duty evasion. The court held that any person (Directors) directly or indirectly involved in projecting proceeds of crime as untainted property is guilty of money laundering u/s 3 of PMLA, punishable u/s 4. The person need not be an accused in the predicate offence. The petitioners' contention of not being involved in the company's day-to-day administration was rejected, as the PMLA complaint was for possession and use of proceeds of crime, not for offences committed as directors. The court reiterated that money laundering is a stand-alone offence distinct from the predicate offence, and the trial court should proceed uninfluenced by observations in this order.
The High Court dismissed the petition challenging the complaint filed under the Prevention of Money Laundering Act (PMLA) for customs duty evasion. The court held that any person (Directors) directly or indirectly involved in projecting proceeds of crime as untainted property is guilty of money laundering u/s 3 of PMLA, punishable u/s 4. The person need not be an accused in the predicate offence. The petitioners' contention of not being involved in the company's day-to-day administration was rejected, as the PMLA complaint was for possession and use of proceeds of crime, not for offences committed as directors. The court reiterated that money laundering is a stand-alone offence distinct from the predicate offence, and the trial court should proceed uninfluenced by observations in this order.
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