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...
Dismissal of Section 9 for initiation of CIRP - Period of limitation - The Adjudicating Authority held that the debt was time-barred as per the Limitation Act. It noted that 26 out of 27 invoices submitted by the Operational Creditor were more than three years old from the date of filing the Section 9 application, and no subsequent acknowledgment of liability was provided to extend the limitation period. - The Tribunal (NCLAT) dismissed the appeal, affirming the Adjudicating Authority's order.
Dismissal of Section 9 for initiation of CIRP - Period of limitation - The Adjudicating Authority held that the debt was time-barred as per the Limitation Act. It noted that 26 out of 27 invoices submitted by the Operational Creditor were more than three years old from the date of filing the Section 9 application, and no subsequent acknowledgment of liability was provided to extend the limitation period. - The Tribunal (NCLAT) dismissed the appeal, affirming the Adjudicating Authority's order.
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