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...
Status quo over the company's assets continues pending valuation and determination of the proposed buyout of the appellant's shareholding. As the remaining dispute concerned alternative buyout relief, and the parties had proposed valuers but no appointment or valuation report had been made, the Tribunal was to appoint a valuer, obtain the report, and independently decide the buyout offer expeditiously. The company appeal was disposed of subject to continuation of the existing status quo until that process is completed.
Status quo over the company's assets continues pending valuation and determination of the proposed buyout of the appellant's shareholding. As the remaining dispute concerned alternative buyout relief, and the parties had proposed valuers but no appointment or valuation report had been made, the Tribunal was to appoint a valuer, obtain the report, and independently decide the buyout offer expeditiously. The company appeal was disposed of subject to continuation of the existing status quo until that process is completed.
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