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...
The text states that the three-month period for filing a bankruptcy application against a personal guarantor is directory, not mandatory, because Section 121(2) uses mandatory language without prescribing any consequence for delay. It further states that delay may be condoned on sufficient cause under the Limitation Act read with Section 238A of the Code, and that a dismissal solely on limitation without reasons is unsustainable. The application was therefore restored for consideration on merits.
The text states that the three-month period for filing a bankruptcy application against a personal guarantor is directory, not mandatory, because Section 121(2) uses mandatory language without prescribing any consequence for delay. It further states that delay may be condoned on sufficient cause under the Limitation Act read with Section 238A of the Code, and that a dismissal solely on limitation without reasons is unsustainable. The application was therefore restored for consideration on merits.
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