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...
Existence of financial debt established through acknowledgment of part payments and promise to pay next installment. Section 10A bar not applicable as default occurred on 05.07.2021. Record of default sufficiently proved through loan documents and Corporate Debtor's admission, satisfying Section 7(3)(a) requirements. Stamping issue inconsequential given established debt and default above threshold. Authorized signatory confirmed through Board Resolution. Debt and default proven, exceeding Rs. 1 crore threshold. Petition admitted, Insolvency Resolution Professional appointed with directions to Financial Creditor regarding remuneration and expenses.
Existence of financial debt established through acknowledgment of part payments and promise to pay next installment. Section 10A bar not applicable as default occurred on 05.07.2021. Record of default sufficiently proved through loan documents and Corporate Debtor's admission, satisfying Section 7(3)(a) requirements. Stamping issue inconsequential given established debt and default above threshold. Authorized signatory confirmed through Board Resolution. Debt and default proven, exceeding Rs. 1 crore threshold. Petition admitted, Insolvency Resolution Professional appointed with directions to Financial Creditor regarding remuneration and expenses.
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