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...
IBC prevails over electricity law where pre-CIRP dues were not included in an approved resolution plan, because Sections 31 and 238 bind all stakeholders and give the plan finality on a clean slate basis. The Court held that statutory electricity authorities are also bound by the resolution plan, and pre-resolution claims not filed during CIRP stand extinguished by operation of law. Public announcement of CIRP was sufficient notice; separate individual service was not required. The impugned demand notices were quashed insofar as they sought recovery of pre-CIRP dues, while liberty was reserved to raise fresh demands only for lawful post-resolution liability.
IBC prevails over electricity law where pre-CIRP dues were not included in an approved resolution plan, because Sections 31 and 238 bind all stakeholders and give the plan finality on a clean slate basis. The Court held that statutory electricity authorities are also bound by the resolution plan, and pre-resolution claims not filed during CIRP stand extinguished by operation of law. Public announcement of CIRP was sufficient notice; separate individual service was not required. The impugned demand notices were quashed insofar as they sought recovery of pre-CIRP dues, while liberty was reserved to raise fresh demands only for lawful post-resolution liability.
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