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...
Attachment of property under PMLA is discussed in the context of alleged proceeds of crime arising from scheduled offences, where the Adjudicating Authority issued a show cause notice on the basis of the original complaint, relied-upon documents and statements under section 50, and later confirmed the provisional attachment. The appeals were carried to the Appellate Tribunal under SAFEMA. A specific contention noted in the source is that attachment of property acquired before 01-07-2005, the commencement of PMLA, is not valid in law; the Tribunal is stated to have dealt with that issue along with the other grounds raised.
Attachment of property under PMLA is discussed in the context of alleged proceeds of crime arising from scheduled offences, where the Adjudicating Authority issued a show cause notice on the basis of the original complaint, relied-upon documents and statements under section 50, and later confirmed the provisional attachment. The appeals were carried to the Appellate Tribunal under SAFEMA. A specific contention noted in the source is that attachment of property acquired before 01-07-2005, the commencement of PMLA, is not valid in law; the Tribunal is stated to have dealt with that issue along with the other grounds raised.
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