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...
Appeal against order filed by Resolution Professional (RP) was disposed of. Resolution Plan submitted by Appellant was approved by Committee of Creditors (CoC) on 07.11.2020. Excise & Taxation Officer's claim was initially allowed by Adjudicating Authority but reversed by Appellate Tribunal, leading to Civil Appeal before Supreme Court. Supreme Court directed completion of process within 90 days. RP filed application seeking directions, which Adjudicating Authority allowed but without specifying process to be conducted. Appellate Tribunal permitted RP to place agenda before CoC regarding necessary steps in Corporate Insolvency Resolution Process as per Supreme Court's directions. CoC, being in overall control, may take decisions and complete process as directed by Supreme Court. Appeal disposed off granting liberty to RP to place appropriate agenda before CoC.
Appeal against order filed by Resolution Professional (RP) was disposed of. Resolution Plan submitted by Appellant was approved by Committee of Creditors (CoC) on 07.11.2020. Excise & Taxation Officer's claim was initially allowed by Adjudicating Authority but reversed by Appellate Tribunal, leading to Civil Appeal before Supreme Court. Supreme Court directed completion of process within 90 days. RP filed application seeking directions, which Adjudicating Authority allowed but without specifying process to be conducted. Appellate Tribunal permitted RP to place agenda before CoC regarding necessary steps in Corporate Insolvency Resolution Process as per Supreme Court's directions. CoC, being in overall control, may take decisions and complete process as directed by Supreme Court. Appeal disposed off granting liberty to RP to place appropriate agenda before CoC.
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