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...
Section 20 of the Prevention of Money-Laundering Act does not cause a freezing order to lapse automatically after 180 days where the Adjudicating Authority has authorised retention or continuation within that period. On the facts, the retention order had been passed in time, so the challenge based on the outer-limit argument failed. The Tribunal also found prima facie material, including the appellant's own statement, showing involvement in facilitating false inspection reports, verification of bank guarantees and processing connected proposals, and noted the failure to disclose the source of the funds in the frozen accounts. The challenge to continued retention was rejected and the appeal dismissed.
Section 20 of the Prevention of Money-Laundering Act does not cause a freezing order to lapse automatically after 180 days where the Adjudicating Authority has authorised retention or continuation within that period. On the facts, the retention order had been passed in time, so the challenge based on the outer-limit argument failed. The Tribunal also found prima facie material, including the appellant's own statement, showing involvement in facilitating false inspection reports, verification of bank guarantees and processing connected proposals, and noted the failure to disclose the source of the funds in the frozen accounts. The challenge to continued retention was rejected and the appeal dismissed.
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