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 application seeking direction to the liquidator to put on hold the auction of the immovable asset of the Corporate Debtor and consider the proposal to sell the Corporate Debtor as a going concern was dismissed. The appellant's resolution plan was previously rejected, and the orders affirming the rejection were not challenged, attaining finality. The relief sought was barred by the principle of res judicata as it had already been denied by the NCLAT. The appellant relinquished the right to question the appointment of the liquidator or seek the requested relief due to the failure to challenge the rejection of the resolution plan. Consequently, the appeal was dismissed.
The application seeking direction to the liquidator to put on hold the auction of the immovable asset of the Corporate Debtor and consider the proposal to sell the Corporate Debtor as a going concern was dismissed. The appellant's resolution plan was previously rejected, and the orders affirming the rejection were not challenged, attaining finality. The relief sought was barred by the principle of res judicata as it had already been denied by the NCLAT. The appellant relinquished the right to question the appointment of the liquidator or seek the requested relief due to the failure to challenge the rejection of the resolution plan. Consequently, the appeal was dismissed.
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