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...
Completed liquidation and sale of a corporate debtor as a going concern can make income-tax appeals on pre-IBC additions infructuous where the liquidation has closed and subsisting NCLT directions require pre-transfer liabilities to be dealt with only within the IBC framework. Because assessments, notices and proceedings for the pre-transfer period were barred against the transferred entity and its successors, the Tribunal treated any merits adjudication as academic and disposed of the appeals without examining the additions. The note also clarifies that the outcome was confined to the corporate debtor and did not decide any independent action against former management or other persons.
Completed liquidation and sale of a corporate debtor as a going concern can make income-tax appeals on pre-IBC additions infructuous where the liquidation has closed and subsisting NCLT directions require pre-transfer liabilities to be dealt with only within the IBC framework. Because assessments, notices and proceedings for the pre-transfer period were barred against the transferred entity and its successors, the Tribunal treated any merits adjudication as academic and disposed of the appeals without examining the additions. The note also clarifies that the outcome was confined to the corporate debtor and did not decide any independent action against former management or other persons.
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