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...
Competing mortgage priorities in liquidation fall within the Adjudicating Authority's jurisdiction where determining encumbrances and liquidation-estate assets is necessary for custody, verification and realisation. Earlier second pari-passu charges moved into priority after discharge of the first mortgage; a later independent simple mortgage remained subordinate under the chronological priority rule, and assignees obtained no better rights than their assignor. Non-registration did not create or defeat the underlying charge as between parties and persons with notice. Failure to elect timely realisation of subordinate security outside liquidation caused the security interest to be treated as part of the liquidation estate, supporting dismissal of the assignee's claim and delivery of title deeds to the Liquidator.
Competing mortgage priorities in liquidation fall within the Adjudicating Authority's jurisdiction where determining encumbrances and liquidation-estate assets is necessary for custody, verification and realisation. Earlier second pari-passu charges moved into priority after discharge of the first mortgage; a later independent simple mortgage remained subordinate under the chronological priority rule, and assignees obtained no better rights than their assignor. Non-registration did not create or defeat the underlying charge as between parties and persons with notice. Failure to elect timely realisation of subordinate security outside liquidation caused the security interest to be treated as part of the liquidation estate, supporting dismissal of the assignee's claim and delivery of title deeds to the Liquidator.
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