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...
The Tribunal granted permission to the Applicant to distribute the unsold assets, being the amount recoverable from the corporate debtor and its erstwhile management under the action initiated against their previous preferential, undervalued and fraudulent transactions among the Respondents. In the 5th SCC meeting, the Liquidator proposed assigning the right to file PUFE proceedings for avoidance/recovery of amounts to VS & B Containers LLC, which was accepted by a 66.82% majority vote. The SCC resolved that if any amounts are recovered, VS & B Containers LLC shall share the recovered amounts with other Shareholders as per their claim sharing ratio. The Tribunal ordered that the right to recover from PUFE proceedings shall be assigned to VS & B Containers LLC, and any amount recovered shall be shared accordingly. The Application was disposed of.
The Tribunal granted permission to the Applicant to distribute the unsold assets, being the amount recoverable from the corporate debtor and its erstwhile management under the action initiated against their previous preferential, undervalued and fraudulent transactions among the Respondents. In the 5th SCC meeting, the Liquidator proposed assigning the right to file PUFE proceedings for avoidance/recovery of amounts to VS & B Containers LLC, which was accepted by a 66.82% majority vote. The SCC resolved that if any amounts are recovered, VS & B Containers LLC shall share the recovered amounts with other Shareholders as per their claim sharing ratio. The Tribunal ordered that the right to recover from PUFE proceedings shall be assigned to VS & B Containers LLC, and any amount recovered shall be shared accordingly. The Application was disposed of.
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