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 PMLA was upheld where the order itself recorded that the immovable property represented proceeds of crime, so there was no need for later supplementation of reasons. The Court held that attachment is confined to property having a nexus with the scheduled offence; property acquired before commission of the offence does not ordinarily fall within the definition of proceeds of crime, and equivalent-value attachment is limited to property derived from criminal activity taken or held outside India. However, the appellant failed to prove on the record that the attached property was in fact acquired before the alleged offence period, so the challenge to attachment failed.
Provisional attachment under the PMLA was upheld where the order itself recorded that the immovable property represented proceeds of crime, so there was no need for later supplementation of reasons. The Court held that attachment is confined to property having a nexus with the scheduled offence; property acquired before commission of the offence does not ordinarily fall within the definition of proceeds of crime, and equivalent-value attachment is limited to property derived from criminal activity taken or held outside India. However, the appellant failed to prove on the record that the attached property was in fact acquired before the alleged offence period, so the challenge to attachment failed.
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