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...
Bona fide plot purchasers whose bookings and registered sale deeds pre-dated liquidation were entitled to release of their plots, because the transactions were verified as genuine, there was no material showing dominant intention to prefer creditors, and the RBI prohibition order did not invalidate completed third-party conveyances. The Court treated them as similarly placed with purchasers who had already obtained final relief, rejected objections based on alleged lack of authorisation, demarcation, bank records and later layout cancellation, and directed handover of the plots. The review petition by the ex-management side was dismissed, as the applicant had no independent locus standi and the attempt was a proxy effort to reopen final winding-up orders concerning verified investor claims.
Bona fide plot purchasers whose bookings and registered sale deeds pre-dated liquidation were entitled to release of their plots, because the transactions were verified as genuine, there was no material showing dominant intention to prefer creditors, and the RBI prohibition order did not invalidate completed third-party conveyances. The Court treated them as similarly placed with purchasers who had already obtained final relief, rejected objections based on alleged lack of authorisation, demarcation, bank records and later layout cancellation, and directed handover of the plots. The review petition by the ex-management side was dismissed, as the applicant had no independent locus standi and the attempt was a proxy effort to reopen final winding-up orders concerning verified investor claims.
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