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...
The pre-packaged insolvency resolution framework is amended to require the resolution professional to appoint registered valuers within three days of appointment to determine fair value and liquidation value, unless the committee records reasons to appoint two sets of valuers. Disqualifications are specified for related parties, recent auditors, partners or directors of the resolution professional's insolvency professional entity, and their relatives. The valuation rules are also revised so that the coordinating valuer's fair value becomes the corporate debtor's fair value, or the average of two coordinating valuations where two sets are appointed. Liquidation value is similarly fixed by the aggregate of valuation estimates, or the aggregate of the averages from two sets where applicable.
The pre-packaged insolvency resolution framework is amended to require the resolution professional to appoint registered valuers within three days of appointment to determine fair value and liquidation value, unless the committee records reasons to appoint two sets of valuers. Disqualifications are specified for related parties, recent auditors, partners or directors of the resolution professional's insolvency professional entity, and their relatives. The valuation rules are also revised so that the coordinating valuer's fair value becomes the corporate debtor's fair value, or the average of two coordinating valuations where two sets are appointed. Liquidation value is similarly fixed by the aggregate of valuation estimates, or the aggregate of the averages from two sets where applicable.
Note: It is a system-generated summary and is for quick reference only.