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...
A non-bailable warrant under the Fugitive Economic Offenders Act remains a jurisdictional prerequisite where it has been issued to secure the accused's production before the Indian court; foreign arrest and bail do not exhaust the warrant if the person is still abroad and resisting return. The Court also held that the statutory monetary threshold for a scheduled offence must be crossed before proceedings under the Act can be sustained, and that the final assessment order quantifying undisclosed foreign income and assets well above that threshold validated the prima facie material. It further held that prosecution for wilful attempt to evade tax under the Black Money Act can proceed alongside assessment, and upheld the declaration of fugitive economic offender.
A non-bailable warrant under the Fugitive Economic Offenders Act remains a jurisdictional prerequisite where it has been issued to secure the accused's production before the Indian court; foreign arrest and bail do not exhaust the warrant if the person is still abroad and resisting return. The Court also held that the statutory monetary threshold for a scheduled offence must be crossed before proceedings under the Act can be sustained, and that the final assessment order quantifying undisclosed foreign income and assets well above that threshold validated the prima facie material. It further held that prosecution for wilful attempt to evade tax under the Black Money Act can proceed alongside assessment, and upheld the declaration of fugitive economic offender.
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