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...
Insolvency law's overriding effect and the clean slate doctrine require that municipal dues be treated as operational debts and be presented to the liquidator for participation in the liquidation waterfall; purchasers at liquidation sales or successful resolution applicants are not liable for pre sale statutory liabilities unless the authority lodged a claim and the debt qualified as a secured interest. Contractual clauses like "as is where is" cannot preserve a municipal charge extinguished or subordinated under the Code. Retrospective revaluation or assessment against post sale purchasers who did not know of or claim the dues is not enforceable, and the impugned assessment notices were set aside with the writ allowed.
Insolvency law's overriding effect and the clean slate doctrine require that municipal dues be treated as operational debts and be presented to the liquidator for participation in the liquidation waterfall; purchasers at liquidation sales or successful resolution applicants are not liable for pre sale statutory liabilities unless the authority lodged a claim and the debt qualified as a secured interest. Contractual clauses like "as is where is" cannot preserve a municipal charge extinguished or subordinated under the Code. Retrospective revaluation or assessment against post sale purchasers who did not know of or claim the dues is not enforceable, and the impugned assessment notices were set aside with the writ allowed.
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