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...
Money deposited in court pursuant to a pre-deposit order was treated as compliance with the court's direction and remained an asset of the corporate debtor; on commencement of CIRP, it had to be released to the resolution professional for distribution under the IBC, with accrued interest included. The supplier's attempt to withdraw the amount was rejected because its claim had to be pursued within the insolvency process. The writ petition challenging the MSME award was also held not maintainable, as an alternate statutory appeal remedy existed under the MSME Act and, independently, section 14 of the IBC barred continuation of proceedings against the corporate debtor after CIRP began.
Money deposited in court pursuant to a pre-deposit order was treated as compliance with the court's direction and remained an asset of the corporate debtor; on commencement of CIRP, it had to be released to the resolution professional for distribution under the IBC, with accrued interest included. The supplier's attempt to withdraw the amount was rejected because its claim had to be pursued within the insolvency process. The writ petition challenging the MSME award was also held not maintainable, as an alternate statutory appeal remedy existed under the MSME Act and, independently, section 14 of the IBC barred continuation of proceedings against the corporate debtor after CIRP began.
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