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 dismissed the appeal and refused to interfere with the Single Judge's order upholding the Provisional Attachment Order under the PMLA, affirming that writ jurisdiction under Article 226 must be exercised sparingly where an alternative efficacious remedy exists and only upon proof of mala fides, patent arbitrariness, or lack of jurisdiction. The Court held a PAO is a provisional safeguard for future PMLA proceedings and non-compliance with the first proviso to s.5(1) is not per se fatal to attachment proceedings. The Court found the designated authority had cogent material to believe proceeds of crime were invested and limited attachment to properties acquired during 2009-2014; quashing was denied.
The HC dismissed the appeal and refused to interfere with the Single Judge's order upholding the Provisional Attachment Order under the PMLA, affirming that writ jurisdiction under Article 226 must be exercised sparingly where an alternative efficacious remedy exists and only upon proof of mala fides, patent arbitrariness, or lack of jurisdiction. The Court held a PAO is a provisional safeguard for future PMLA proceedings and non-compliance with the first proviso to s.5(1) is not per se fatal to attachment proceedings. The Court found the designated authority had cogent material to believe proceeds of crime were invested and limited attachment to properties acquired during 2009-2014; quashing was denied.
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