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...
For enforcement of a foreign arbitral award, Article 137 applies and limitation runs from accrual of the right to apply, which may arise on communication of the signed award rather than invariably on the award date; on the facts stated, the petition was timely because the award was communicated later. The public policy objection failed because refusal of enforcement is confined narrowly to Section 48 grounds, and the transaction was treated as a commercial arrangement rather than a factoring transaction requiring registration. Joint and several liability under the award meant pursuit of one debtor did not bar action against another absent clear waiver or novation; the forbearance agreement did not extinguish liability.
For enforcement of a foreign arbitral award, Article 137 applies and limitation runs from accrual of the right to apply, which may arise on communication of the signed award rather than invariably on the award date; on the facts stated, the petition was timely because the award was communicated later. The public policy objection failed because refusal of enforcement is confined narrowly to Section 48 grounds, and the transaction was treated as a commercial arrangement rather than a factoring transaction requiring registration. Joint and several liability under the award meant pursuit of one debtor did not bar action against another absent clear waiver or novation; the forbearance agreement did not extinguish liability.
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