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...
SC upheld the COFEPOSA detention orders, holding that the detenus had no enforceable right to legal representation before the Advisory Board where the detaining or sponsoring authorities did not appear through counsel, and mere production of records by officers was not participation. It further found substantial compliance with the duty to supply relied upon material, as the pen drive contents were shown in prison and the relied upon documents, including translations, were furnished. The Court also accepted that communications rejecting the representations were ministerial acts conveying decisions already taken by competent authorities. Adequate subjective satisfaction, a live and proximate nexus, and the likelihood of release on bail were also established, so both petitions were dismissed.
SC upheld the COFEPOSA detention orders, holding that the detenus had no enforceable right to legal representation before the Advisory Board where the detaining or sponsoring authorities did not appear through counsel, and mere production of records by officers was not participation. It further found substantial compliance with the duty to supply relied upon material, as the pen drive contents were shown in prison and the relied upon documents, including translations, were furnished. The Court also accepted that communications rejecting the representations were ministerial acts conveying decisions already taken by competent authorities. Adequate subjective satisfaction, a live and proximate nexus, and the likelihood of release on bail were also established, so both petitions were dismissed.
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