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...
Provisional attachment lapses by operation of law once the prescribed one-year period expires, so continued freezing of bank accounts cannot be sustained. On that basis, the attachment was treated as having automatically ceased, and the petitioner was allowed to operate the accounts. Separately, cash credit accounts are not liable to provisional attachment, making their freezing independently unsustainable. The bank-account freeze, including the cash credit facilities, was therefore held to have come to an end, while all other contentions were left open.
Provisional attachment lapses by operation of law once the prescribed one-year period expires, so continued freezing of bank accounts cannot be sustained. On that basis, the attachment was treated as having automatically ceased, and the petitioner was allowed to operate the accounts. Separately, cash credit accounts are not liable to provisional attachment, making their freezing independently unsustainable. The bank-account freeze, including the cash credit facilities, was therefore held to have come to an end, while all other contentions were left open.
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