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 resolution plan was rejected because material non-compliances in the CIRP, including inadequate disclosure of avoidance/PUFE transactions, non-transparent handling of those proceedings, and lapses in performance security, undermined the fairness of the process. The Appellate Tribunal held that the Committee of Creditors' commercial wisdom could not cure defects where other applicants were deprived of material information and the plan proceeded on incomplete disclosure. It also upheld adverse findings against the erstwhile resolution professional, noting unsatisfactory explanations for failures in dealing with avoidance applications and security compliance. Both appeals were dismissed, and the direction to investigate the resolution professional's conduct was maintained.
A resolution plan was rejected because material non-compliances in the CIRP, including inadequate disclosure of avoidance/PUFE transactions, non-transparent handling of those proceedings, and lapses in performance security, undermined the fairness of the process. The Appellate Tribunal held that the Committee of Creditors' commercial wisdom could not cure defects where other applicants were deprived of material information and the plan proceeded on incomplete disclosure. It also upheld adverse findings against the erstwhile resolution professional, noting unsatisfactory explanations for failures in dealing with avoidance applications and security compliance. Both appeals were dismissed, and the direction to investigate the resolution professional's conduct was maintained.
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