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 BankruptcyNovember 22, 2022Case LawsAT
Approval of the Resolution Plan - discriminatory plan - Farmers were given 100% of the dues whereas the Appellant has given only 1% of the dues - there is no embargo for the classification of the ‘Operational Creditors’ into separate/different classes for deciding the way in which the money is to be distributed to them by the CoCs. - AT
Approval of the Resolution Plan - discriminatory plan - Farmers were given 100% of the dues whereas the Appellant has given only 1% of the dues - there is no embargo for the classification of the ‘Operational Creditors’ into separate/different classes for deciding the way in which the money is to be distributed to them by the CoCs. - AT
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