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...
High Court considered enlargement on bail for a foreign national accused of tax evasion; offence is triable by a Magistrate with a maximum sentence of five years. The court found documentary and electronic evidence present but no convincing material of a real risk of tampering, and noted immigration status (expired visa with pending extension) and family circumstances. Having balanced these factors and the nature of the offence, the court granted bail subject to verification of identity, status and residential proof of sureties by the trial court and warned that breach of conditions would permit bail cancellation and remand.
High Court considered enlargement on bail for a foreign national accused of tax evasion; offence is triable by a Magistrate with a maximum sentence of five years. The court found documentary and electronic evidence present but no convincing material of a real risk of tampering, and noted immigration status (expired visa with pending extension) and family circumstances. Having balanced these factors and the nature of the offence, the court granted bail subject to verification of identity, status and residential proof of sureties by the trial court and warned that breach of conditions would permit bail cancellation and remand.
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