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 DSC refused bail to Accused A in a prosecution under Sections 132(1)(b), (c) and (i) of the CGST Act, 2017, arising from an alleged large-scale fraudulent generation, claim and transmission of Input Tax Credit and refund claims approximating Rs.29.81 crore through nongenuine supplier firms. The court found material indicating fabrication of firms, misuse of identity documents, filing of a refund application on behalf of Firm X without authorization, abscondence to the USA, recurrent change of residence and alteration of personal identifiers, and earlier proclamation as a fugitive, collectively demonstrating strong grounds to believe culpability and high flight risk. In view of the gravity of the economic offence and governing precedents, bail was denied.
The DSC refused bail to Accused A in a prosecution under Sections 132(1)(b), (c) and (i) of the CGST Act, 2017, arising from an alleged large-scale fraudulent generation, claim and transmission of Input Tax Credit and refund claims approximating Rs.29.81 crore through nongenuine supplier firms. The court found material indicating fabrication of firms, misuse of identity documents, filing of a refund application on behalf of Firm X without authorization, abscondence to the USA, recurrent change of residence and alteration of personal identifiers, and earlier proclamation as a fugitive, collectively demonstrating strong grounds to believe culpability and high flight risk. In view of the gravity of the economic offence and governing precedents, bail was denied.
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