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...
Ambiguity in service of orders by NCLT; Role of Insolvency and Bankruptcy Board of India (IBBI) - The Supreme Court decided to involve the Insolvency and Bankruptcy Board of India (IBBI) to address these issues. The IBBI was tasked with examining whether the existing process required any clarification, modification, or simplification to ensure smoother proceedings in such cases.
Ambiguity in service of orders by NCLT; Role of Insolvency and Bankruptcy Board of India (IBBI) - The Supreme Court decided to involve the Insolvency and Bankruptcy Board of India (IBBI) to address these issues. The IBBI was tasked with examining whether the existing process required any clarification, modification, or simplification to ensure smoother proceedings in such cases.
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