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...
Interpretation of Regulation 21A of IBBI (Liquidation Process) Regulations, 2016 regarding secured creditor's obligation to realize security interest within stipulated time. Regulation casts duty on secured creditor to pay liquidator estimated amount or excess realized value within prescribed timeline, failing which asset becomes part of liquidation estate. Secured creditor's contention of non-communication of estimated amount by liquidator rejected as misplaced. Law mandates secured creditor to complete realization process within 180 days, after which asset vests with liquidation estate under Regulation 21A(3). Secured creditor's belated claim over remaining property portion rejected for non-compliance with 30-day intimation requirement. Liquidator's decision upheld as per regulations. Application dismissed by Tribunal.
Interpretation of Regulation 21A of IBBI (Liquidation Process) Regulations, 2016 regarding secured creditor's obligation to realize security interest within stipulated time. Regulation casts duty on secured creditor to pay liquidator estimated amount or excess realized value within prescribed timeline, failing which asset becomes part of liquidation estate. Secured creditor's contention of non-communication of estimated amount by liquidator rejected as misplaced. Law mandates secured creditor to complete realization process within 180 days, after which asset vests with liquidation estate under Regulation 21A(3). Secured creditor's belated claim over remaining property portion rejected for non-compliance with 30-day intimation requirement. Liquidator's decision upheld as per regulations. Application dismissed by Tribunal.
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