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...
HC held that the initial provisional attachment order ceased by efflux of time after one year and, in absence of statutory authority for renewal or re-issuance, executive authorities lack power to impose provisional attachment repeatedly; such repetition amounts to executive overreach. The impugned order dated 1 May 2025 effecting a fourth attachment of the petitioner's bank account is quashed and set aside. The authorities are directed to de-freeze the petitioner's bank account forthwith, and in any event within three days from the date of the order. The petition is disposed of.
HC held that the initial provisional attachment order ceased by efflux of time after one year and, in absence of statutory authority for renewal or re-issuance, executive authorities lack power to impose provisional attachment repeatedly; such repetition amounts to executive overreach. The impugned order dated 1 May 2025 effecting a fourth attachment of the petitioner's bank account is quashed and set aside. The authorities are directed to de-freeze the petitioner's bank account forthwith, and in any event within three days from the date of the order. The petition is disposed of.
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