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...
Arbitral awards on prolongation costs, GST reimbursement, minimum-wage escalation, Environmental Compensation Charges and taxes were upheld under Section 34 because the tribunal had adopted a plausible view on the contract, delay attribution and quantification of damages. The court treated the prolongation-cost methodology as a permissible estimate based on record and industry practice, and refused re-appreciation of evidence. It also sustained reimbursement for GST introduced during the extended period, held that a minimum-wage escalation bar could not defeat compensation for employer-caused delay, and accepted ECC as an additional charge not clearly barred by the exclusion clause. The majority award was treated as binding, and no patent illegality or perversity was shown.
Arbitral awards on prolongation costs, GST reimbursement, minimum-wage escalation, Environmental Compensation Charges and taxes were upheld under Section 34 because the tribunal had adopted a plausible view on the contract, delay attribution and quantification of damages. The court treated the prolongation-cost methodology as a permissible estimate based on record and industry practice, and refused re-appreciation of evidence. It also sustained reimbursement for GST introduced during the extended period, held that a minimum-wage escalation bar could not defeat compensation for employer-caused delay, and accepted ECC as an additional charge not clearly barred by the exclusion clause. The majority award was treated as binding, and no patent illegality or perversity was shown.
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