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...
High Court reviewed a magistrate's refusal to allow a director to travel abroad where corporate entities had been penalised for alleged bogus input tax credits. The Court held that corporate penalties and revenue loss alone do not justify depriving an individual of personal liberty or the right to travel abroad; absent material showing personal flight risk or intent to evade process, travel may be permitted. The Court applied principles protecting personal liberty, weighed offence gravity and case stage, and allowed travel subject to conditions including a security deposit, itinerary and passport disclosure and cooperation with investigators.
High Court reviewed a magistrate's refusal to allow a director to travel abroad where corporate entities had been penalised for alleged bogus input tax credits. The Court held that corporate penalties and revenue loss alone do not justify depriving an individual of personal liberty or the right to travel abroad; absent material showing personal flight risk or intent to evade process, travel may be permitted. The Court applied principles protecting personal liberty, weighed offence gravity and case stage, and allowed travel subject to conditions including a security deposit, itinerary and passport disclosure and cooperation with investigators.
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