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...
Foundational loan documents seriously disputed as forged or fabricated can take a Section 7 insolvency petition beyond summary admission, especially where multiple versions of the facility agreement, inconsistent dates and signatures, and board resolutions not matching company records create a genuine fraud inquiry. The tribunal treated the alleged disbursal into an unauthorised account as relevant to whether a binding financial debt and default were established, and held that the doctrine of indoor management was unavailable where the transaction circumstances showed suspicion of irregularity. On that basis, dismissal of the petition was upheld.
Foundational loan documents seriously disputed as forged or fabricated can take a Section 7 insolvency petition beyond summary admission, especially where multiple versions of the facility agreement, inconsistent dates and signatures, and board resolutions not matching company records create a genuine fraud inquiry. The tribunal treated the alleged disbursal into an unauthorised account as relevant to whether a binding financial debt and default were established, and held that the doctrine of indoor management was unavailable where the transaction circumstances showed suspicion of irregularity. On that basis, dismissal of the petition was upheld.
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