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 BankruptcyDecember 16, 2022Case LawsAT
Condonation of delay of 17 days in filing of appeal - last two days being public holidays - Power of Jurisdiction of NCLAT to condone delay - Applicability of provisions of limitation act - We are of the view that the Appeal was not filed beyond the delay of 15 days. Filing of the Appeal was within the delay of 15 days, this Court can very well consider the grounds for condonation of 15 days delay. - AT
Condonation of delay of 17 days in filing of appeal - last two days being public holidays - Power of Jurisdiction of NCLAT to condone delay - Applicability of provisions of limitation act - We are of the view that the Appeal was not filed beyond the delay of 15 days. Filing of the Appeal was within the delay of 15 days, this Court can very well consider the grounds for condonation of 15 days delay. - AT
Note: It is a system-generated summary and is for quick reference only.