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 HC allowed the petition, holding that the impugned bail order dated 07.06.2025 was unsustainable and therefore set aside and quashed. The Court distinguished between cancellation and setting aside of bail, exercised jurisdiction under the relevant provisions invoked, and found the Authorization to Arrest and Grounds of Arrest adequately disclosed prima facie materials of fraudulent availment of substantial ineligible ITC against the respondents. The arrest on 05.06.2025 was held lawful and compliant with statutory mandates and administrative guidelines; deficiencies in the notice to relatives did not prejudice the respondents who were represented at bail hearings. Petition allowed; impugned order set aside and quashed.
The HC allowed the petition, holding that the impugned bail order dated 07.06.2025 was unsustainable and therefore set aside and quashed. The Court distinguished between cancellation and setting aside of bail, exercised jurisdiction under the relevant provisions invoked, and found the Authorization to Arrest and Grounds of Arrest adequately disclosed prima facie materials of fraudulent availment of substantial ineligible ITC against the respondents. The arrest on 05.06.2025 was held lawful and compliant with statutory mandates and administrative guidelines; deficiencies in the notice to relatives did not prejudice the respondents who were represented at bail hearings. Petition allowed; impugned order set aside and quashed.
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