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...
Continuation of a pre-liquidation aircraft sale process is not barred merely because liquidation begins, where the sale had been approved during the insolvency process and was later adopted by the Stakeholders' Consultation Committee. No material irregularity or illegality was established in completing the sale. Former employees could not challenge the transaction on that basis; their entitlement remained limited to recovery of dues under the statutory liquidation waterfall. The challenge to the sale and the related order was dismissed.
Continuation of a pre-liquidation aircraft sale process is not barred merely because liquidation begins, where the sale had been approved during the insolvency process and was later adopted by the Stakeholders' Consultation Committee. No material irregularity or illegality was established in completing the sale. Former employees could not challenge the transaction on that basis; their entitlement remained limited to recovery of dues under the statutory liquidation waterfall. The challenge to the sale and the related order was dismissed.
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