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...
Right to travel under Article 21 is affirmed as an essential aspect of dignity, but subject to proportionality of liberty-restricting conditions; courts must require a tangible and real flight-risk before imposing travel bars, and may exercise inherent jurisdiction to secure the ends of justice by imposing reasonable conditions rather than total prohibition. Applying those principles, the High Court found the petitioner's foreign business travel was not shown to be an actual flight risk and that denial would disproportionately harm family and commercial interests, and accordingly quashed the lower court order restricting travel.
Right to travel under Article 21 is affirmed as an essential aspect of dignity, but subject to proportionality of liberty-restricting conditions; courts must require a tangible and real flight-risk before imposing travel bars, and may exercise inherent jurisdiction to secure the ends of justice by imposing reasonable conditions rather than total prohibition. Applying those principles, the High Court found the petitioner's foreign business travel was not shown to be an actual flight risk and that denial would disproportionately harm family and commercial interests, and accordingly quashed the lower court order restricting travel.
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