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...
The High Court declined to examine the merits of the challenge to the show cause notice and ex parte adjudication order, holding that the petitioner had already attempted to pursue the statutory appellate remedy and had made the required pre-deposit. As the appeal could not be uploaded on the portal because of a technical glitch, the Court directed the petitioner to file the appeal afresh under the proviso to Rule 108 of the CGST Rules, 2017, permitted all grounds to be raised before the appellate authority, and condoned the delay in filing. The writ petition was disposed of in favour of pursuing the statutory remedy.
The High Court declined to examine the merits of the challenge to the show cause notice and ex parte adjudication order, holding that the petitioner had already attempted to pursue the statutory appellate remedy and had made the required pre-deposit. As the appeal could not be uploaded on the portal because of a technical glitch, the Court directed the petitioner to file the appeal afresh under the proviso to Rule 108 of the CGST Rules, 2017, permitted all grounds to be raised before the appellate authority, and condoned the delay in filing. The writ petition was disposed of in favour of pursuing the statutory remedy.
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