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...
Respondent granted permission to travel abroad to Dubai and Europe by HC subject to conditions. Investigation pending since 06.06.2022 in FIR registered on 13.04.2021, no chargesheet filed. Respondent cooperated with investigating agencies when summoned, disclosed required information. Appellant failed to disclose timeframe for concluding pending investigations. Respondent cannot be deprived of right to travel abroad in such circumstances. No infirmity found in Single Judge's order imposing conditions while granting travel permission. LPA dismissed.
Respondent granted permission to travel abroad to Dubai and Europe by HC subject to conditions. Investigation pending since 06.06.2022 in FIR registered on 13.04.2021, no chargesheet filed. Respondent cooperated with investigating agencies when summoned, disclosed required information. Appellant failed to disclose timeframe for concluding pending investigations. Respondent cannot be deprived of right to travel abroad in such circumstances. No infirmity found in Single Judge's order imposing conditions while granting travel permission. LPA dismissed.
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