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...
Territorial jurisdiction under Article 226(2) is satisfied because the principal cause of action-the debit freezing of the petitioner's bank account-arose within the Court's territorial limits, permitting a writ petition challenging that freeze. The court applied the principle that a legal right infringed within territorial limits supports jurisdiction and distinguished prior authority where only a minor part of cause of action arose locally. The order holds that debit-freezing directed by police on January 6, 2025, lacked requisite magistrate-sanctioned seizure or attachment and is therefore quashed; the bank must restore account operation.
Territorial jurisdiction under Article 226(2) is satisfied because the principal cause of action-the debit freezing of the petitioner's bank account-arose within the Court's territorial limits, permitting a writ petition challenging that freeze. The court applied the principle that a legal right infringed within territorial limits supports jurisdiction and distinguished prior authority where only a minor part of cause of action arose locally. The order holds that debit-freezing directed by police on January 6, 2025, lacked requisite magistrate-sanctioned seizure or attachment and is therefore quashed; the bank must restore account operation.
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