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 amendment regulations expand and standardise the personal guarantor insolvency framework by removing clause (e) in regulation 3, replacing prescribed Forms A, B and C with forms notified by circular, and inserting a detailed statement-of-assets requirement for applications under sections 94 and 95. The new disclosure covers cash, business interests, investments, immovable property, retirement benefits, digital assets, intellectual property, valuables, agricultural assets, receivables, contingent claims, ESOPs and beneficial interests, including assets held indirectly, jointly, fiduciary or through nominees and other arrangements. They also introduce a coordination and creditor-approval mechanism for transfer of assets in related corporate insolvency proceedings and align certain procedural provisions with sections 106 and 28A.
The amendment regulations expand and standardise the personal guarantor insolvency framework by removing clause (e) in regulation 3, replacing prescribed Forms A, B and C with forms notified by circular, and inserting a detailed statement-of-assets requirement for applications under sections 94 and 95. The new disclosure covers cash, business interests, investments, immovable property, retirement benefits, digital assets, intellectual property, valuables, agricultural assets, receivables, contingent claims, ESOPs and beneficial interests, including assets held indirectly, jointly, fiduciary or through nominees and other arrangements. They also introduce a coordination and creditor-approval mechanism for transfer of assets in related corporate insolvency proceedings and align certain procedural provisions with sections 106 and 28A.
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