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...
The Tribunal upheld attachment under the PMLA after finding valid service of the show cause notice, complaint and relied upon documents, and therefore no breach of natural justice or denial of hearing. It further held that property attached as proceeds of crime or the value thereof remains liable to attachment even if acquired before the alleged offence period, because the statute treats direct proceeds and their value alike. It also confirmed attachment of assets standing in a spouse's name or jointly held, holding that attachment is not limited to an accused in the scheduled offence but extends to any person involved in activity connected with proceeds of crime. Both appeals were dismissed.
The Tribunal upheld attachment under the PMLA after finding valid service of the show cause notice, complaint and relied upon documents, and therefore no breach of natural justice or denial of hearing. It further held that property attached as proceeds of crime or the value thereof remains liable to attachment even if acquired before the alleged offence period, because the statute treats direct proceeds and their value alike. It also confirmed attachment of assets standing in a spouse's name or jointly held, holding that attachment is not limited to an accused in the scheduled offence but extends to any person involved in activity connected with proceeds of crime. Both appeals were dismissed.
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