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...
Assessment/reassessment proceedings against an insolvent company were quashed. A resolution plan was approved by the Tribunal u/s 30(6) of the Insolvency and Bankruptcy Code. The claim lodged by the Deputy Commissioner of Income Tax was verified and admitted during the NCLT proceedings. As per the Code's provisions, no person can initiate or continue proceedings regarding claims for dues relating to the period prior to the resolution plan's approval. Consequently, the Assessment Order passed u/ss 147, 144, and 144B, the order u/s 148A(d), and the notices u/s 148A(b) were quashed and set aside, favoring the assessee.
Assessment/reassessment proceedings against an insolvent company were quashed. A resolution plan was approved by the Tribunal u/s 30(6) of the Insolvency and Bankruptcy Code. The claim lodged by the Deputy Commissioner of Income Tax was verified and admitted during the NCLT proceedings. As per the Code's provisions, no person can initiate or continue proceedings regarding claims for dues relating to the period prior to the resolution plan's approval. Consequently, the Assessment Order passed u/ss 147, 144, and 144B, the order u/s 148A(d), and the notices u/s 148A(b) were quashed and set aside, favoring the assessee.
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