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...
A general board resolution authorising an officer to sign and file documents was sufficient to file the section 7 applications; no fresh post-Code authorisation was required, so the objection to locus failed. The underlying transaction constituted financial debt because the agreement separately treated the construction advance as an interest-bearing unsecured loan with repayment and penal-interest terms, and it was reflected as unsecured borrowing in the balance sheet; the contrary finding was set aside. The alleged related-party and section 65 fraud findings were unsustainable for want of specific statutory pleading and proof, and penalty under section 65 could not be imposed on the corporate debtors. As debt and default stood established, the section 7 applications were directed to be admitted.
A general board resolution authorising an officer to sign and file documents was sufficient to file the section 7 applications; no fresh post-Code authorisation was required, so the objection to locus failed. The underlying transaction constituted financial debt because the agreement separately treated the construction advance as an interest-bearing unsecured loan with repayment and penal-interest terms, and it was reflected as unsecured borrowing in the balance sheet; the contrary finding was set aside. The alleged related-party and section 65 fraud findings were unsustainable for want of specific statutory pleading and proof, and penalty under section 65 could not be imposed on the corporate debtors. As debt and default stood established, the section 7 applications were directed to be admitted.
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