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...
NCLAT held that a concluded liquidation auction could not be set aside merely because a higher price was expected where the e-auction was publicly advertised, properly conducted, and free from fraud, collusion, underbidding or any fundamental procedural defect. It found that the earlier Lot 2 bid covered the entire area, while the additional land emerged as a separate plot after subdivision; the liquidator's earlier communications were only part of a price-discovery exercise and not a private sale. The successful bidder was an aggrieved person entitled to appeal, and the order for re-auction was reversed, with the sale restored and the sale certificate directed to be issued.
NCLAT held that a concluded liquidation auction could not be set aside merely because a higher price was expected where the e-auction was publicly advertised, properly conducted, and free from fraud, collusion, underbidding or any fundamental procedural defect. It found that the earlier Lot 2 bid covered the entire area, while the additional land emerged as a separate plot after subdivision; the liquidator's earlier communications were only part of a price-discovery exercise and not a private sale. The successful bidder was an aggrieved person entitled to appeal, and the order for re-auction was reversed, with the sale restored and the sale certificate directed to be issued.
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