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...
NCLAT dismissed the appeal challenging liquidated damages deduction from corporate debtor's invoices. The Appellate Tribunal held that liquidated damages deducted during contract performance per purchase order terms remain valid, and the approved resolution plan does not retrospectively invalidate such deductions. The tribunal affirmed the Adjudicating Authority's decision, emphasizing that contract terms prevail and no refund is mandated for damages legitimately assessed during contract execution, even after corporate insolvency resolution process initiation.
NCLAT dismissed the appeal challenging liquidated damages deduction from corporate debtor's invoices. The Appellate Tribunal held that liquidated damages deducted during contract performance per purchase order terms remain valid, and the approved resolution plan does not retrospectively invalidate such deductions. The tribunal affirmed the Adjudicating Authority's decision, emphasizing that contract terms prevail and no refund is mandated for damages legitimately assessed during contract execution, even after corporate insolvency resolution process initiation.
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