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...
Rejection of the simultaneous claim by the Resolution Professional of the Corporate Debtor - Claim filed by the Applicant with respect to the corporate guarantee given by the Corporate Debtor - the claim can not be rejected merely on the ground that the claim has already been admitted in CIRP of M/s. Sitex. Moreover, there is no bar in the IBC, 2016 to submit the simultaneous claim in the CIRP of the Corporate Debtor as well as in the CIRP of the corporate guarantor. - Tri
Rejection of the simultaneous claim by the Resolution Professional of the Corporate Debtor - Claim filed by the Applicant with respect to the corporate guarantee given by the Corporate Debtor - the claim can not be rejected merely on the ground that the claim has already been admitted in CIRP of M/s. Sitex. Moreover, there is no bar in the IBC, 2016 to submit the simultaneous claim in the CIRP of the Corporate Debtor as well as in the CIRP of the corporate guarantor. - Tri
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