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...
Expiry of an insolvency professional's authorisation on attaining 70 years did not end an ongoing assignment, because Regulation 7A's proviso preserved assignments already in progress when authorisation expired; the Bankruptcy Trustee was allowed to continue and complete the work. The challenge to removal on that ground was rejected. The challenge to extension of the liquidation period was also dismissed because the extension had already expired by the time the appeal was heard, and interference would have been academic; the decision to seek extension had been treated as valid. Both appeals were dismissed.
Expiry of an insolvency professional's authorisation on attaining 70 years did not end an ongoing assignment, because Regulation 7A's proviso preserved assignments already in progress when authorisation expired; the Bankruptcy Trustee was allowed to continue and complete the work. The challenge to removal on that ground was rejected. The challenge to extension of the liquidation period was also dismissed because the extension had already expired by the time the appeal was heard, and interference would have been academic; the decision to seek extension had been treated as valid. Both appeals were dismissed.
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