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...
Contractual and development rights under a hire-purchase development arrangement may form part of the corporate debtor's insolvency assets even where land title remains with a statutory authority. Such rights are limited to the debtor's existing contractual entitlement and cannot divest third-party ownership, compel land transfer, or bypass statutory requirements for compounding or regularising unauthorised construction. The notes distinguish pre-CIRP sealing and confiscation for unauthorised construction from actions barred by the moratorium, and state that physical possession does not by itself determine land rights. A resolution plan must identify surviving contractual rights, respect third-party title, and address the availability of required statutory approvals.
Contractual and development rights under a hire-purchase development arrangement may form part of the corporate debtor's insolvency assets even where land title remains with a statutory authority. Such rights are limited to the debtor's existing contractual entitlement and cannot divest third-party ownership, compel land transfer, or bypass statutory requirements for compounding or regularising unauthorised construction. The notes distinguish pre-CIRP sealing and confiscation for unauthorised construction from actions barred by the moratorium, and state that physical possession does not by itself determine land rights. A resolution plan must identify surviving contractual rights, respect third-party title, and address the availability of required statutory approvals.
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