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...
Transfer of pending winding up proceedings under the statutory transfer scheme can be ordered even without a party application, because Section 434(1)(c) requires assessment of the stage of liquidation and whether it has become irreversible or irretrievable. On the facts, only possession of assets had been taken and the immovable properties remained unsold, so liquidation had not crossed that stage. The transfer order was therefore a valid exercise of jurisdiction and the challenge failed.
Transfer of pending winding up proceedings under the statutory transfer scheme can be ordered even without a party application, because Section 434(1)(c) requires assessment of the stage of liquidation and whether it has become irreversible or irretrievable. On the facts, only possession of assets had been taken and the immovable properties remained unsold, so liquidation had not crossed that stage. The transfer order was therefore a valid exercise of jurisdiction and the challenge failed.
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