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...
Rejection of Section 10 application under IBC upheld as Appellant company filed it with unclean hands after evading Wilful Defaulter proceedings by Respondent Bank. Appellant selectively approached Bank for reprieve while avoiding proceedings, embroiling Bank in multiple litigations to stall recovery. Section 10 rights can't be misused to derive undue advantage over insolvency resolution objective. Adjudicating Authority rightly found Appellant's bonafides doubtful, filing motivated by reasons other than insolvency resolution. Appeal dismissed by NCLAT.
Rejection of Section 10 application under IBC upheld as Appellant company filed it with unclean hands after evading Wilful Defaulter proceedings by Respondent Bank. Appellant selectively approached Bank for reprieve while avoiding proceedings, embroiling Bank in multiple litigations to stall recovery. Section 10 rights can't be misused to derive undue advantage over insolvency resolution objective. Adjudicating Authority rightly found Appellant's bonafides doubtful, filing motivated by reasons other than insolvency resolution. Appeal dismissed by NCLAT.
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