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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Post-approval tariff revision did not create an independent right to refund or set-off for pre-CIRP electricity dues where the approved resolution plan had already settled and frozen pre-CIRP liabilities inter se the parties. The revised bills were treated only as an internal accounting adjustment reflecting the reduced extent of the respondent's pre-CIRP claim and bad debt, not as an enforceable fresh demand against the appellant beyond the plan amount. Since no additional pre-CIRP liability was fastened, the requests for adjustment and refund were not maintainable, and the reconnection prayer did not survive separately because a direction had already been issued.
Post-approval tariff revision did not create an independent right to refund or set-off for pre-CIRP electricity dues where the approved resolution plan had already settled and frozen pre-CIRP liabilities inter se the parties. The revised bills were treated only as an internal accounting adjustment reflecting the reduced extent of the respondent's pre-CIRP claim and bad debt, not as an enforceable fresh demand against the appellant beyond the plan amount. Since no additional pre-CIRP liability was fastened, the requests for adjustment and refund were not maintainable, and the reconnection prayer did not survive separately because a direction had already been issued.
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