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...
Admission of the corporate insolvency resolution process may rest on an undisputed record of default filed with an information utility, together with other material establishing that the corporate debtor availed the loans. For a financial creditor's application, the adjudicating authority must ascertain default from information utility records or other evidence furnished. Where the debtor does not dispute the pleaded default date, objections that loan documents are photocopies do not invalidate admission. The challenge to admission was rejected and the writ petition was dismissed without costs.
Admission of the corporate insolvency resolution process may rest on an undisputed record of default filed with an information utility, together with other material establishing that the corporate debtor availed the loans. For a financial creditor's application, the adjudicating authority must ascertain default from information utility records or other evidence furnished. Where the debtor does not dispute the pleaded default date, objections that loan documents are photocopies do not invalidate admission. The challenge to admission was rejected and the writ petition was dismissed without costs.
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