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...
Bail was refused in a prosecution alleging clandestine manufacture and duty evasion under a capacity-based excise regime tied to installed packing machines. The Court held that disputed questions about actual production, machine utilisation and exact duty liability could not be decided at the bail stage, and that the applicant's claim that one machine was non-functional did not prima facie displace the statutory scheme absent a prior declaration to the competent Commissioner. Seizure of machines, raw materials and finished goods, together with Section 70 statements, furnished prima facie material of concealment and clandestine manufacture. Given the economic-offence character of the ations, continuing investigation and risk of tampering with evidence or influencing witnesses, the application was dismissed.
Bail was refused in a prosecution alleging clandestine manufacture and duty evasion under a capacity-based excise regime tied to installed packing machines. The Court held that disputed questions about actual production, machine utilisation and exact duty liability could not be decided at the bail stage, and that the applicant's claim that one machine was non-functional did not prima facie displace the statutory scheme absent a prior declaration to the competent Commissioner. Seizure of machines, raw materials and finished goods, together with Section 70 statements, furnished prima facie material of concealment and clandestine manufacture. Given the economic-offence character of the ations, continuing investigation and risk of tampering with evidence or influencing witnesses, the application was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
