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...
Limitation under the Insolvency and Bankruptcy Code is strict, time-bound and jurisdictional: an appeal must be filed in defect-free form within the statutory outer limit, and a defective presentation cannot be perfected at leisure. The procedural period for removing defects or seeking condonation of re-filing delay under the Supreme Court Rules cannot override the Code's timeline. Once the outer limit and the defect-cure period are both exhausted, the right of appeal stands extinguished and no condonation survives. The plea for a liberal approach, including the appellant's status as liquidator and reliance on Article 142, was rejected, and sufficient cause was not shown in any event.
Limitation under the Insolvency and Bankruptcy Code is strict, time-bound and jurisdictional: an appeal must be filed in defect-free form within the statutory outer limit, and a defective presentation cannot be perfected at leisure. The procedural period for removing defects or seeking condonation of re-filing delay under the Supreme Court Rules cannot override the Code's timeline. Once the outer limit and the defect-cure period are both exhausted, the right of appeal stands extinguished and no condonation survives. The plea for a liberal approach, including the appellant's status as liquidator and reliance on Article 142, was rejected, and sufficient cause was not shown in any event.
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