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...
Initiation of CIRP - Period of Limitation - Exclusion of certain period - NCLT rejected the application - The Adjudicating Authority has committed error in rejecting the Application filed under Section 9 by the Appellant as barred by time. A perusal of the order of the Adjudicating Authority indicates that only two grounds were considered by the Adjudicating Authority, that is, Application having barred by time and pre-existing dispute as raised by the Corporate Debtor - matter is remitted to the Adjudicating Authority to pass an order of admission on Section 9 Application after giving an opportunity to the parties to enter into settlement. - AT
Initiation of CIRP - Period of Limitation - Exclusion of certain period - NCLT rejected the application - The Adjudicating Authority has committed error in rejecting the Application filed under Section 9 by the Appellant as barred by time. A perusal of the order of the Adjudicating Authority indicates that only two grounds were considered by the Adjudicating Authority, that is, Application having barred by time and pre-existing dispute as raised by the Corporate Debtor - matter is remitted to the Adjudicating Authority to pass an order of admission on Section 9 Application after giving an opportunity to the parties to enter into settlement. - AT
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