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...
Summons issued during a GST inquiry constitute an evidence-gathering measure and do not themselves initiate prosecutorial proceedings; therefore the summonses challenged were held valid and within statutory power. The court treated arrest safeguards under the relevant arrest provision as distinct and emphasised procedural protections for arrest, while noting anticipatory bail is not appropriate merely to avoid appearance during an inquiry stage - anticipatory relief was premature and the writ dismissed for lack of readiness. The court also recorded non-cooperation by petitioners and noted one petitioner had already been released on bail, leaving liberty to seek appropriate relief at a later stage.
Summons issued during a GST inquiry constitute an evidence-gathering measure and do not themselves initiate prosecutorial proceedings; therefore the summonses challenged were held valid and within statutory power. The court treated arrest safeguards under the relevant arrest provision as distinct and emphasised procedural protections for arrest, while noting anticipatory bail is not appropriate merely to avoid appearance during an inquiry stage - anticipatory relief was premature and the writ dismissed for lack of readiness. The court also recorded non-cooperation by petitioners and noted one petitioner had already been released on bail, leaving liberty to seek appropriate relief at a later stage.
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