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 second charge created under a consent decree and consequential deed of charge was upheld as a valid security interest where the first charge holder's priority remained expressly preserved and the second charge operated only after discharge of the first charge. The Tribunal held that absence of the first charge holder's prior consent did not render the second charge a nullity, and the liquidator was bound by the decree and deed. It also held that Regulation 21 of the Liquidation Process Regulations is enabling, not exhaustive, so security interest may be proved by other valid material. Non-registration under Section 77 of the Companies Act was not, by itself, enough to deny secured status. The appeal was dismissed.
A second charge created under a consent decree and consequential deed of charge was upheld as a valid security interest where the first charge holder's priority remained expressly preserved and the second charge operated only after discharge of the first charge. The Tribunal held that absence of the first charge holder's prior consent did not render the second charge a nullity, and the liquidator was bound by the decree and deed. It also held that Regulation 21 of the Liquidation Process Regulations is enabling, not exhaustive, so security interest may be proved by other valid material. Non-registration under Section 77 of the Companies Act was not, by itself, enough to deny secured status. The appeal was dismissed.
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