Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
The court addressed whether bail should be granted where prosecution relied on stereotyped witness statements, co-accused confessions, supplementary charge-sheet material obtained without prior leave, and documentary/digital evidence. It found the rice-miller statements prima facie verbatim and mechanically recorded-weakening their probative value-while reiterating that co-accused statements can only corroborate and not solely implicate; the supplementary material collected post charge-sheet cannot prejudice liberty. No contemporaneous documents link the applicant to policy decisions, and there is no specific material showing risk of flight, tampering or influencing witnesses. Balancing these factors and custody already undergone, bail was granted subject to conditions. - HC
The court addressed whether bail should be granted where prosecution relied on stereotyped witness statements, co-accused confessions, supplementary charge-sheet material obtained without prior leave, and documentary/digital evidence. It found the rice-miller statements prima facie verbatim and mechanically recorded-weakening their probative value-while reiterating that co-accused statements can only corroborate and not solely implicate; the supplementary material collected post charge-sheet cannot prejudice liberty. No contemporaneous documents link the applicant to policy decisions, and there is no specific material showing risk of flight, tampering or influencing witnesses. Balancing these factors and custody already undergone, bail was granted subject to conditions. - HC
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