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 29, 2024Case LawsAT
CIRP - Admission of Section 7 application - The tribunal meticulously assessed evidence, including correspondence, loan agreements, and bank statements, to determine the existence and timing of defaults. It found the appellant's admission of default in correspondence significant and rejected arguments of uncertainty regarding default dates. Additionally, the tribunal clarified that the moratorium applied only to principal amounts, not interest payments, as per restructuring terms. - In conclusion, the tribunal upheld the decision to admit the Section 7 application, dismissing the appeal.
CIRP - Admission of Section 7 application - The tribunal meticulously assessed evidence, including correspondence, loan agreements, and bank statements, to determine the existence and timing of defaults. It found the appellant's admission of default in correspondence significant and rejected arguments of uncertainty regarding default dates. Additionally, the tribunal clarified that the moratorium applied only to principal amounts, not interest payments, as per restructuring terms. - In conclusion, the tribunal upheld the decision to admit the Section 7 application, dismissing the appeal.
Note: It is a system-generated summary and is for quick reference only.