Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Anticipatory bail in a Customs investigation was granted because adjudicatory proceedings had already commenced, a show cause notice had been issued, and the applicant was participating in that process. The court also noted the absence of criminal antecedents, no alleged breach during a prolonged ad-interim protection period, and that the matter largely turned on documentary evidence available to the investigating agency. On that basis, it held that the applicant's presence could be secured through conditions and that custodial interrogation was unnecessary. Bail was allowed subject to conditions ensuring attendance and cooperation with the investigation.
Anticipatory bail in a Customs investigation was granted because adjudicatory proceedings had already commenced, a show cause notice had been issued, and the applicant was participating in that process. The court also noted the absence of criminal antecedents, no alleged breach during a prolonged ad-interim protection period, and that the matter largely turned on documentary evidence available to the investigating agency. On that basis, it held that the applicant's presence could be secured through conditions and that custodial interrogation was unnecessary. Bail was allowed subject to conditions ensuring attendance and cooperation with the investigation.
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