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...
Implementation of the Resolution Plan and change in management and control - Demand of customs duty - The appellant did not file any claim during the insolvency process, and as per provisions of the IBC, once a resolution plan is approved, all claims not part of the plan stand extinguished. The Court referred to relevant sections of the IBC and a Supreme Court ruling, affirming that once a resolution plan is approved, claims not included cease to exist. Consequently, the appeal was deemed abated, and the questions proposed were not answered.
Implementation of the Resolution Plan and change in management and control - Demand of customs duty - The appellant did not file any claim during the insolvency process, and as per provisions of the IBC, once a resolution plan is approved, all claims not part of the plan stand extinguished. The Court referred to relevant sections of the IBC and a Supreme Court ruling, affirming that once a resolution plan is approved, claims not included cease to exist. Consequently, the appeal was deemed abated, and the questions proposed were not answered.
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