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...
Corporate insolvency admission requires the outstanding default on the date of admission to meet the statutory minimum threshold. Part-payments made before admission reduce the debt in default for this purpose, and financial creditors must disclose those payments to the Adjudicating Authority. Where the remaining default falls below the threshold, admission of the insolvency application cannot be sustained. The admission was set aside because pre-admission repayments reduced the outstanding default below the applicable minimum, and CIRP costs were directed to be borne by the appellant.
Corporate insolvency admission requires the outstanding default on the date of admission to meet the statutory minimum threshold. Part-payments made before admission reduce the debt in default for this purpose, and financial creditors must disclose those payments to the Adjudicating Authority. Where the remaining default falls below the threshold, admission of the insolvency application cannot be sustained. The admission was set aside because pre-admission repayments reduced the outstanding default below the applicable minimum, and CIRP costs were directed to be borne by the appellant.
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