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...
Doctrine of necessity invoked to grant opportunity to deposit balance amount into liquidation account to avoid liquidation and enable Corporate Debtor to revive as going concern. Section 60(5) of Insolvency and Bankruptcy Code, 2016 empowers Tribunal to pass appropriate order to meet Code's objective despite contrary provisions. Appellant granted last chance to deposit amount within one month, failing which relaxation lapses and liquidator can seek alternate buyer as per law. Appeal disposed of.
Doctrine of necessity invoked to grant opportunity to deposit balance amount into liquidation account to avoid liquidation and enable Corporate Debtor to revive as going concern. Section 60(5) of Insolvency and Bankruptcy Code, 2016 empowers Tribunal to pass appropriate order to meet Code's objective despite contrary provisions. Appellant granted last chance to deposit amount within one month, failing which relaxation lapses and liquidator can seek alternate buyer as per law. Appeal disposed of.
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