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...
Rejection of claim filed by appellant - Appellant states that the Respondent / CD, did not perform its part of the contract from its inception and did not establish the letters of credit as contemplated - The Tribunal concurs with the Respondent that claims lacking supporting documents cannot be admitted. It upholds the Liquidator's decision to reject claims that lack substantiation and require adjudication by a competent civil court or arbitrator. Regarding the role of the Liquidator, the Tribunal agrees that her actions align with the IBC and Liquidation Regulations. She is obligated to verify claims based on available information and is not empowered to adjudicate disputes between parties.
Rejection of claim filed by appellant - Appellant states that the Respondent / CD, did not perform its part of the contract from its inception and did not establish the letters of credit as contemplated - The Tribunal concurs with the Respondent that claims lacking supporting documents cannot be admitted. It upholds the Liquidator's decision to reject claims that lack substantiation and require adjudication by a competent civil court or arbitrator. Regarding the role of the Liquidator, the Tribunal agrees that her actions align with the IBC and Liquidation Regulations. She is obligated to verify claims based on available information and is not empowered to adjudicate disputes between parties.
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