Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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The NCLAT held that appellants could not later complain of lack of notice or hearing where they were represented by counsel when the interlocutory applications were taken up, since knowledge of the proceedings and an opportunity to object were attributable to them. It further upheld exclusion of 208 days from the personal guarantor insolvency resolution process, ruling that the period spent in earlier appeals could be excluded to give effect to prior appellate directions and that the statutory time limit operates as a moratorium-related provision, not as a bar on exclusion of time for effective continuation of the process. The exclusion was treated as a procedural measure and the appeals were dismissed.
The NCLAT held that appellants could not later complain of lack of notice or hearing where they were represented by counsel when the interlocutory applications were taken up, since knowledge of the proceedings and an opportunity to object were attributable to them. It further upheld exclusion of 208 days from the personal guarantor insolvency resolution process, ruling that the period spent in earlier appeals could be excluded to give effect to prior appellate directions and that the statutory time limit operates as a moratorium-related provision, not as a bar on exclusion of time for effective continuation of the process. The exclusion was treated as a procedural measure and the appeals were dismissed.
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