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...
Resolution professional was entitled to cooperation, project records and access from a party operating under project agreements because, once CIRP commenced, the RP had a statutory duty to preserve and protect the corporate debtor's assets. The tribunal held that the matter was not a mere contractual dispute and directed disclosure of documents and information, but declined to stop construction because continuation was necessary in the interest of stakeholders, especially homebuyers. It also held that unregistered development documents did not create title in immovable property, so the project remained with the corporate debtor, while the earlier registered mortgage over the land, units and receivables continued and was not displaced by later development arrangements.
Resolution professional was entitled to cooperation, project records and access from a party operating under project agreements because, once CIRP commenced, the RP had a statutory duty to preserve and protect the corporate debtor's assets. The tribunal held that the matter was not a mere contractual dispute and directed disclosure of documents and information, but declined to stop construction because continuation was necessary in the interest of stakeholders, especially homebuyers. It also held that unregistered development documents did not create title in immovable property, so the project remained with the corporate debtor, while the earlier registered mortgage over the land, units and receivables continued and was not displaced by later development arrangements.
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