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 Adjudicating Authority had the power to recall its earlier order, which contained factual mistakes, and pass a corrected order regarding the return of the Corporate Debtor's engine and APU, which were in the Appellant's possession and of greater value. The Appellate Tribunal held that the Adjudicating Authority did not review or recall its earlier order but corrected genuine mistakes based on mistaken facts. The power to recall a judgment can be exercised when the ground for reopening was not available or pleaded earlier, and no other remedy was available. The Adjudicating Authority correctly passed the impugned order, and the appeal was dismissed.
The Adjudicating Authority had the power to recall its earlier order, which contained factual mistakes, and pass a corrected order regarding the return of the Corporate Debtor's engine and APU, which were in the Appellant's possession and of greater value. The Appellate Tribunal held that the Adjudicating Authority did not review or recall its earlier order but corrected genuine mistakes based on mistaken facts. The power to recall a judgment can be exercised when the ground for reopening was not available or pleaded earlier, and no other remedy was available. The Adjudicating Authority correctly passed the impugned order, and the appeal was dismissed.
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