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, dealing with a petition under s.70(2) Cr.P.C. seeking conversion of arrest warrants into bailable warrants in an alleged large-scale tax evasion case, noted conflicting views of different Co-ordinate Benches on the scope of such power in economic and heinous offences. Observing absence of a settled legal position and the need for uniformity, the HC refrained from deciding the petitioner's claim on merits. Instead, it referred the core question-whether an accused in economic or heinous offences can, as a matter of right, seek conversion of arrest warrants into bailable warrants under ss.70(2) Cr.P.C. and 72(2) BNSS-to a Special/Larger Bench, to be constituted by the Chief Justice.
The HC, dealing with a petition under s.70(2) Cr.P.C. seeking conversion of arrest warrants into bailable warrants in an alleged large-scale tax evasion case, noted conflicting views of different Co-ordinate Benches on the scope of such power in economic and heinous offences. Observing absence of a settled legal position and the need for uniformity, the HC refrained from deciding the petitioner's claim on merits. Instead, it referred the core question-whether an accused in economic or heinous offences can, as a matter of right, seek conversion of arrest warrants into bailable warrants under ss.70(2) Cr.P.C. and 72(2) BNSS-to a Special/Larger Bench, to be constituted by the Chief Justice.
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