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 - Liquidation proceedings - Rejection of claim of Yes Bank for transfer of VAT refund to the account of FEMC Pratibha JV - non relinquishing of security interest as part of liquidation estate - The Appellate Tribunal upheld the Adjudicating Authority's decision, dismissing the appeal. The VAT refund was correctly transferred to the Corporate Debtor's account, and Yes Bank's failure to comply with Regulation 21A justified the inclusion of secured assets in the liquidation estate. The appeal lacked merit and was dismissed.
CIRP - Liquidation proceedings - Rejection of claim of Yes Bank for transfer of VAT refund to the account of FEMC Pratibha JV - non relinquishing of security interest as part of liquidation estate - The Appellate Tribunal upheld the Adjudicating Authority's decision, dismissing the appeal. The VAT refund was correctly transferred to the Corporate Debtor's account, and Yes Bank's failure to comply with Regulation 21A justified the inclusion of secured assets in the liquidation estate. The appeal lacked merit and was dismissed.
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