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...
Invocation of a continuing guarantee by demand was treated as the point when liability became enforceable, so the Section 95 insolvency application against the personal guarantor was held to be within limitation because the demand notice preceded the filing date. The creditor's debt and default were found sufficiently established through the guarantee and acknowledgment, audited balance sheets showing borrowings, and admission of the claim in liquidation proceedings; discrepancies in the amounts stated across proceedings did not defeat admission at that stage. Allegations of conflict of interest against the resolution professional were not accepted as a ground to interfere with the admission order, though the merits of that allegation were left open. The appeal was dismissed.
Invocation of a continuing guarantee by demand was treated as the point when liability became enforceable, so the Section 95 insolvency application against the personal guarantor was held to be within limitation because the demand notice preceded the filing date. The creditor's debt and default were found sufficiently established through the guarantee and acknowledgment, audited balance sheets showing borrowings, and admission of the claim in liquidation proceedings; discrepancies in the amounts stated across proceedings did not defeat admission at that stage. Allegations of conflict of interest against the resolution professional were not accepted as a ground to interfere with the admission order, though the merits of that allegation were left open. The appeal was dismissed.
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