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...
CIRP - Dismissal of application filed u/s 7 of the Insolvency and Bankruptcy Code, 2016 - Distinction between financial debt owed by the Corporate Debtor and the lack of privity of contract between the parties. - Despite claims by the appellants that the money was not repaid, the Tribunal found that there was no legal obligation on the part of the Corporate Debtor to repay the loan disbursed to the vendor. The Tribunal highlighted the lack of evidence supporting the money given as a loan, leading to the dismissal of the application under Section 7 of the IBC.
CIRP - Dismissal of application filed u/s 7 of the Insolvency and Bankruptcy Code, 2016 - Distinction between financial debt owed by the Corporate Debtor and the lack of privity of contract between the parties. - Despite claims by the appellants that the money was not repaid, the Tribunal found that there was no legal obligation on the part of the Corporate Debtor to repay the loan disbursed to the vendor. The Tribunal highlighted the lack of evidence supporting the money given as a loan, leading to the dismissal of the application under Section 7 of the IBC.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
