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...
Committee of Creditors may reconsider a resolution plan at any time before the Adjudicating Authority approves it, including after remand to address statutory stakeholder claims. Directions requiring provision for provident fund, gratuity and other claims became final when unchallenged. Although the resolution applicant sought revision, it declined to increase the plan value when the remanded plan was reconsidered. The Committee of Creditors' commercial decision to reject the plan and proceed with liquidation was treated as non-justiciable in these circumstances. The proposed plan's rejection and the challenge to that rejection were upheld, with no basis for appellate interference.
Committee of Creditors may reconsider a resolution plan at any time before the Adjudicating Authority approves it, including after remand to address statutory stakeholder claims. Directions requiring provision for provident fund, gratuity and other claims became final when unchallenged. Although the resolution applicant sought revision, it declined to increase the plan value when the remanded plan was reconsidered. The Committee of Creditors' commercial decision to reject the plan and proceed with liquidation was treated as non-justiciable in these circumstances. The proposed plan's rejection and the challenge to that rejection were upheld, with no basis for appellate interference.
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