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...
Prosecution materials disclosed a prima facie case of money-laundering where Section 50 PMLA statements, seized diaries, cash recovery and related records indicated collection and distribution of tender commission through the petitioner's associates and personal secretary. The Court held that Section 50 statements are admissible and can form reliable material at the discharge stage, that money-laundering is an independent offence, and that the petitioner need not be named in the scheduled offence if the material shows involvement with proceeds of crime. It also rejected the plea of want of previous sanction, holding that the alleged acts were not part of official duty. The discharge refusal and charge framing were upheld.
Prosecution materials disclosed a prima facie case of money-laundering where Section 50 PMLA statements, seized diaries, cash recovery and related records indicated collection and distribution of tender commission through the petitioner's associates and personal secretary. The Court held that Section 50 statements are admissible and can form reliable material at the discharge stage, that money-laundering is an independent offence, and that the petitioner need not be named in the scheduled offence if the material shows involvement with proceeds of crime. It also rejected the plea of want of previous sanction, holding that the alleged acts were not part of official duty. The discharge refusal and charge framing were upheld.
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