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...
Provisional attachment under the Prevention of Money Laundering regime may be ordered against a person or entity in possession of proceeds of crime even if not formally accused; the tribunal applied the principles that challenge to the prosecution complaint does not suspend attachment proceedings while criminal proceedings remain pending and that existence of parallel FIRs sustaining the scheduled offence permits continuation. The Adjudicating Authority's confirmation of provisional attachment was upheld on material showing receipt of proceeds by the appellants, and the appeals were dismissed for lack of merit.
Provisional attachment under the Prevention of Money Laundering regime may be ordered against a person or entity in possession of proceeds of crime even if not formally accused; the tribunal applied the principles that challenge to the prosecution complaint does not suspend attachment proceedings while criminal proceedings remain pending and that existence of parallel FIRs sustaining the scheduled offence permits continuation. The Adjudicating Authority's confirmation of provisional attachment was upheld on material showing receipt of proceeds by the appellants, and the appeals were dismissed for lack of merit.
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