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...
Entitlement to regular bail in alleged fraudulent availment of input tax credit was allowed where the court found that allegations were documentary, records were already with the department, and further custodial interrogation would be purposeless; the petitioner had been detained since 03.11.2025 and trial was likely to be protracted given voluminous documents. The offences are magistrate-triable with limited sentences; precedents on similar bail grants and the protection of personal liberty informed the exercise of discretion. Bail was granted subject to furnishing bonds and the trial court was directed to proceed expeditiously; no opinion was expressed on merits.
Entitlement to regular bail in alleged fraudulent availment of input tax credit was allowed where the court found that allegations were documentary, records were already with the department, and further custodial interrogation would be purposeless; the petitioner had been detained since 03.11.2025 and trial was likely to be protracted given voluminous documents. The offences are magistrate-triable with limited sentences; precedents on similar bail grants and the protection of personal liberty informed the exercise of discretion. Bail was granted subject to furnishing bonds and the trial court was directed to proceed expeditiously; no opinion was expressed on merits.
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