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 Hon'ble Delhi High Court held that grounds of arrest must be communicated in writing to the arrested person, relying on Supreme Court judgments. It distinguished between 'reasons for arrest' and 'grounds of arrest'. 'Grounds of arrest' require details necessitating the accused's arrest to provide opportunity for defending against custodial remand and seeking bail. Instruction amended to mandate furnishing grounds of arrest in writing as annexure to arrest memo and taking acknowledgment.
The Hon'ble Delhi High Court held that grounds of arrest must be communicated in writing to the arrested person, relying on Supreme Court judgments. It distinguished between 'reasons for arrest' and 'grounds of arrest'. 'Grounds of arrest' require details necessitating the accused's arrest to provide opportunity for defending against custodial remand and seeking bail. Instruction amended to mandate furnishing grounds of arrest in writing as annexure to arrest memo and taking acknowledgment.
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