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 Appellate Tribunal held that the definition of 'proceeds of crime' encompasses not only the property derived or obtained directly or indirectly from criminal activity, but also any other property of equivalent value when the original proceeds are unavailable. The Adjudicating Authority's narrow interpretation of the definition was incorrect. The Tribunal set aside the Adjudicating Authority's order and remanded the case for fresh consideration within the statutory period, with parties to remain present on 10.12.2024. The appeal was allowed.
The Appellate Tribunal held that the definition of 'proceeds of crime' encompasses not only the property derived or obtained directly or indirectly from criminal activity, but also any other property of equivalent value when the original proceeds are unavailable. The Adjudicating Authority's narrow interpretation of the definition was incorrect. The Tribunal set aside the Adjudicating Authority's order and remanded the case for fresh consideration within the statutory period, with parties to remain present on 10.12.2024. The appeal was allowed.
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