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 Supreme Court reiterated the paramount importance of the right to life and liberty under Article 21 of the Constitution, emphasizing that prolonged incarceration of an accused awaiting trial unjustly deprives them of personal liberty. The grant of bail must be determined based on unique circumstances, balanced against factors like the gravity of the offence, likelihood of interference with the investigation, possibility of evidence tampering, threat to witnesses, societal impact, and risk of absconding. Since the charge sheet has been filed but charges are yet to be framed in the ED Case, the Trial Court is directed to decide on framing charges before the winter vacations or 31.12.2024, whichever is earlier, and thereafter fix a date within the second and third week of January 2025 for recording statements of the most material or vulnerable prosecution witnesses. The petition is disposed of.
The Supreme Court reiterated the paramount importance of the right to life and liberty under Article 21 of the Constitution, emphasizing that prolonged incarceration of an accused awaiting trial unjustly deprives them of personal liberty. The grant of bail must be determined based on unique circumstances, balanced against factors like the gravity of the offence, likelihood of interference with the investigation, possibility of evidence tampering, threat to witnesses, societal impact, and risk of absconding. Since the charge sheet has been filed but charges are yet to be framed in the ED Case, the Trial Court is directed to decide on framing charges before the winter vacations or 31.12.2024, whichever is earlier, and thereafter fix a date within the second and third week of January 2025 for recording statements of the most material or vulnerable prosecution witnesses. The petition is disposed of.
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