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
Admission of Section 7 application under IBC - The Appellant contests the admission, citing the submission of a One Time Settlement (OTS) proposal and the Reserve Bank of India (RBI) circular regarding OTS proposals. - The Tribunal acknowledges the OTS proposal and the Bank's 'no objection' for deferring the pronouncement of the order. However, it emphasizes the need for justice and provides an opportunity for the Appellant to deposit the offered amount within 90 days. The Tribunal also addresses the validity of Section 10-A of IBC, directing the deposit of the offered amount within the specified time frame. Overall, the Tribunal focuses on resolving the matter effectively while ensuring fairness and justice.
Admission of Section 7 application under IBC - The Appellant contests the admission, citing the submission of a One Time Settlement (OTS) proposal and the Reserve Bank of India (RBI) circular regarding OTS proposals. - The Tribunal acknowledges the OTS proposal and the Bank's 'no objection' for deferring the pronouncement of the order. However, it emphasizes the need for justice and provides an opportunity for the Appellant to deposit the offered amount within 90 days. The Tribunal also addresses the validity of Section 10-A of IBC, directing the deposit of the offered amount within the specified time frame. Overall, the Tribunal focuses on resolving the matter effectively while ensuring fairness and justice.
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