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...
Section 96 of the Insolvency and Bankruptcy Code creates an interim moratorium from the filing of an application under Sections 94 or 95 until admission, staying pending debt proceedings and barring fresh legal action on the debt during that period. A money recovery suit filed while that embargo operated was therefore barred by law and liable to rejection under Order VII Rule 11(d). The later insertion of Section 96(4) did not cure an earlier filing, and lack of knowledge of the insolvency proceedings was immaterial because the bar operated by statute. The plaint could not be split against some defendants on a joint and several liability theory once the statutory prohibition applied.
Section 96 of the Insolvency and Bankruptcy Code creates an interim moratorium from the filing of an application under Sections 94 or 95 until admission, staying pending debt proceedings and barring fresh legal action on the debt during that period. A money recovery suit filed while that embargo operated was therefore barred by law and liable to rejection under Order VII Rule 11(d). The later insertion of Section 96(4) did not cure an earlier filing, and lack of knowledge of the insolvency proceedings was immaterial because the bar operated by statute. The plaint could not be split against some defendants on a joint and several liability theory once the statutory prohibition applied.
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