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...
Sanction of composite scheme of amalgamation - The appellants contested the order, arguing that it failed to consider certain clauses of the scheme, particularly regarding separability. They sought approval for part D of the scheme, excluding parts B and C, which had been automatically revoked due to non-approval by relevant shareholders. - The Tribunal examined the issues raised and found that the impugned order did not adequately address the separability of the scheme. It recognized the appellants' argument for separability and the Tribunal's discretion to modify arrangements for proper implementation. - Consequently the Tribunal set aside the impugned order and directed the NCLT to reconsider the application for the second motion, taking into account the observations made.
Sanction of composite scheme of amalgamation - The appellants contested the order, arguing that it failed to consider certain clauses of the scheme, particularly regarding separability. They sought approval for part D of the scheme, excluding parts B and C, which had been automatically revoked due to non-approval by relevant shareholders. - The Tribunal examined the issues raised and found that the impugned order did not adequately address the separability of the scheme. It recognized the appellants' argument for separability and the Tribunal's discretion to modify arrangements for proper implementation. - Consequently the Tribunal set aside the impugned order and directed the NCLT to reconsider the application for the second motion, taking into account the observations made.
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