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...
A pending appeal abated because the appellant company had been ordered into liquidation and no application for continuance was filed by the official liquidator under Rule 22 of the CESTAT Procedure Rules. The Tribunal applied Rule 22, which bars continuation of an appeal by a wound-up company unless the liquidator seeks to carry it on, and relied on Ghanshyam Mishra to confirm that the proceedings did not survive. The miscellaneous application was disposed of, and the delay in filing it was condoned.
A pending appeal abated because the appellant company had been ordered into liquidation and no application for continuance was filed by the official liquidator under Rule 22 of the CESTAT Procedure Rules. The Tribunal applied Rule 22, which bars continuation of an appeal by a wound-up company unless the liquidator seeks to carry it on, and relied on Ghanshyam Mishra to confirm that the proceedings did not survive. The miscellaneous application was disposed of, and the delay in filing it was condoned.
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