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...
DSC ruling on petitioner's lawful arrest in tax evasion matter. Despite allegations of procedural irregularities, court found arrest memo valid, with proper grounds explained to accused and her father. Authorization order under Section 69 was signed by accused and witnesses. Court determined further judicial custody unnecessary, noting revenue adequately secured and accused's willingness to cooperate. Considering gender and nature of offense, bail application granted, allowing petitioner's release, with understanding that investigation may continue. Arrest deemed legally sound, but continued detention deemed unwarranted.
DSC ruling on petitioner's lawful arrest in tax evasion matter. Despite allegations of procedural irregularities, court found arrest memo valid, with proper grounds explained to accused and her father. Authorization order under Section 69 was signed by accused and witnesses. Court determined further judicial custody unnecessary, noting revenue adequately secured and accused's willingness to cooperate. Considering gender and nature of offense, bail application granted, allowing petitioner's release, with understanding that investigation may continue. Arrest deemed legally sound, but continued detention deemed unwarranted.
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