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...
Pecuniary Jurisdiction - whether non-payment of TDS amount is debt or not - Present is a case where the Operational Creditor has misused the process of I&B Code in filing application for revival of Section 9 Application for non-payment of two TDS amounts. The process of I&B Code cannot be utilized for the above purpose, whereas present is not a case that Corporate Debtor has not paid any amount due to the Operational Creditor. The Operational Creditor has misused the process of I&B Code. - AT
Pecuniary Jurisdiction - whether non-payment of TDS amount is debt or not - Present is a case where the Operational Creditor has misused the process of I&B Code in filing application for revival of Section 9 Application for non-payment of two TDS amounts. The process of I&B Code cannot be utilized for the above purpose, whereas present is not a case that Corporate Debtor has not paid any amount due to the Operational Creditor. The Operational Creditor has misused the process of I&B Code. - AT
Note: It is a system-generated summary and is for quick reference only.