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...
Impleadment of the appellant bank as Proposed 2nd Respondent, in main Company Appeal - necessary/proper party - The Tribunal noted that the bank's interest was protected under pari passu charge and not an exclusive charge. It further highlighted that the bank had previously acquiesced to decisions made without its impleadment, demonstrating that its participation was not crucial for the resolution of the main appeal. - It was determined that the first respondent/appellant was not entitled to possession once the lease expired. The Tribunal rejected the appellant's argument for a right to stay based on investment in the property, citing lack of a valid, enduring lease agreement beyond the explicitly stated term.
Impleadment of the appellant bank as Proposed 2nd Respondent, in main Company Appeal - necessary/proper party - The Tribunal noted that the bank's interest was protected under pari passu charge and not an exclusive charge. It further highlighted that the bank had previously acquiesced to decisions made without its impleadment, demonstrating that its participation was not crucial for the resolution of the main appeal. - It was determined that the first respondent/appellant was not entitled to possession once the lease expired. The Tribunal rejected the appellant's argument for a right to stay based on investment in the property, citing lack of a valid, enduring lease agreement beyond the explicitly stated term.
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