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 addressed a dispute regarding an onerous Leave and License Agreement under Regulation 10 of Liquidation Regulations. The Tribunal unanimously held that the transaction dated 07.06.2019 was unprofitable and burdensome, qualifying as an onerous property. Both Technical and Judicial Members concurred that the liquidator could disclaim the contract. The Tribunal definitively ruled that Regulation 10 is not ultra vires to the Insolvency and Bankruptcy Code, as it was validly enacted under Section 35(1)(o). Consequently, the NCLAT dismissed the appeal, upholding the adjudicating authority's original order and confirming the liquidator's power to disclaim the onerous property.
NCLAT addressed a dispute regarding an onerous Leave and License Agreement under Regulation 10 of Liquidation Regulations. The Tribunal unanimously held that the transaction dated 07.06.2019 was unprofitable and burdensome, qualifying as an onerous property. Both Technical and Judicial Members concurred that the liquidator could disclaim the contract. The Tribunal definitively ruled that Regulation 10 is not ultra vires to the Insolvency and Bankruptcy Code, as it was validly enacted under Section 35(1)(o). Consequently, the NCLAT dismissed the appeal, upholding the adjudicating authority's original order and confirming the liquidator's power to disclaim the onerous property.
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