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...
In Section 7 insolvency proceedings, intervention by a third party is not warranted merely because it claims an interest under an unregistered agreement for sale. The Appellate Tribunal held that Order I Rule 10 CPC principles may guide, but do not directly govern, the Code; the relevant inquiry is whether the person is a necessary or proper party to adjudication of the financial creditor's claim against the corporate debtor on default. Because the appellant held no conveyance and its claim, if any, lay only against the corporate debtor, it had no legal status requiring impleadment. The refusal to intervene was upheld.
In Section 7 insolvency proceedings, intervention by a third party is not warranted merely because it claims an interest under an unregistered agreement for sale. The Appellate Tribunal held that Order I Rule 10 CPC principles may guide, but do not directly govern, the Code; the relevant inquiry is whether the person is a necessary or proper party to adjudication of the financial creditor's claim against the corporate debtor on default. Because the appellant held no conveyance and its claim, if any, lay only against the corporate debtor, it had no legal status requiring impleadment. The refusal to intervene was upheld.
Note: It is a system-generated summary and is for quick reference only.