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 BankruptcyMarch 20, 2024Case LawsAT
Initiation of CIRP - Failure to make deposits the entire OTS amount - In the interests of justice, the Tribunal directed the appellants and the investor to deposit the agreed amounts within ten days before the National Company Law Tribunal (NCLT) by way of Fixed Deposit Receipts (FDRs) in favor of the NCLT Registrar. It clarified that the Adjudicating Authority would decide on the Section 7 application based on these deposits.
Initiation of CIRP - Failure to make deposits the entire OTS amount - In the interests of justice, the Tribunal directed the appellants and the investor to deposit the agreed amounts within ten days before the National Company Law Tribunal (NCLT) by way of Fixed Deposit Receipts (FDRs) in favor of the NCLT Registrar. It clarified that the Adjudicating Authority would decide on the Section 7 application based on these deposits.
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