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...
Limitation for a personal guarantor's insolvency application begins when the guarantee is invoked. Section 18 of the Limitation Act creates a fresh limitation period only through a written acknowledgment by the party against whom the creditor asserts the right. A personal guarantor cannot rely on unilateral one-time settlement proposals to extend limitation for an application filed by the guarantor; those proposals may operate as admissions usable by the creditor against the guarantor. The Section 94 application was therefore time-barred, and dismissal of both the application and the challenge to the auction notice was upheld.
Limitation for a personal guarantor's insolvency application begins when the guarantee is invoked. Section 18 of the Limitation Act creates a fresh limitation period only through a written acknowledgment by the party against whom the creditor asserts the right. A personal guarantor cannot rely on unilateral one-time settlement proposals to extend limitation for an application filed by the guarantor; those proposals may operate as admissions usable by the creditor against the guarantor. The Section 94 application was therefore time-barred, and dismissal of both the application and the challenge to the auction notice was upheld.
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