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...
Insolvency and BankruptcySeptember 5, 2022Case LawsAT
Rejection of application for initiation of CIRP - Simply rejection of this Appeal may not serve the purpose. Instead it is intended to dismiss the present appeal with imposing heavy cost. There are many circumstances which have been discussed suggests that either lending loan by the appellants were only paper transaction/sham transaction or said loans were shown to be repaid within one or two days from the date of lending. - The Appellants are directed to deposit the cost of Rs.1 lakh in the account of PMNRF - AT
Rejection of application for initiation of CIRP - Simply rejection of this Appeal may not serve the purpose. Instead it is intended to dismiss the present appeal with imposing heavy cost. There are many circumstances which have been discussed suggests that either lending loan by the appellants were only paper transaction/sham transaction or said loans were shown to be repaid within one or two days from the date of lending. - The Appellants are directed to deposit the cost of Rs.1 lakh in the account of PMNRF - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
