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...
Liability of Purchaser of corporate debtor under liquidation under auction - Certain demand raised by the liquidator - now post the execution of the Sale Certificate, the demand raised by the Liquidator to the Applicant for the Interest as well as TDS is not maintainable. The Liquidator is at liberty to file for refund with the Income Tax department for the refund of TDS, if any, applicable to this case. The Liquidator is also directed to hand over the possession of the Corporate Debtors assets as per Schedule I of the Sale Certificate to the Applicant. - Tri
Liability of Purchaser of corporate debtor under liquidation under auction - Certain demand raised by the liquidator - now post the execution of the Sale Certificate, the demand raised by the Liquidator to the Applicant for the Interest as well as TDS is not maintainable. The Liquidator is at liberty to file for refund with the Income Tax department for the refund of TDS, if any, applicable to this case. The Liquidator is also directed to hand over the possession of the Corporate Debtors assets as per Schedule I of the Sale Certificate to the Applicant. - Tri
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