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...
Limitation for an appeal under section 61 of the Insolvency and Bankruptcy Code runs from the date of pronouncement of the impugned order, not from the date of upload or the appellant's date of knowledge. The tribunal applied the statutory time-bound appellate scheme and held that the order pronounced on 08.12.2025 triggered limitation from that date. It also held that an alleged technical glitch in the e-filing portal could not justify condonation once the appeal was filed beyond the maximum condonable period of thirty days plus fifteen days, because the tribunal lacked jurisdiction to entertain a delayed appeal on equitable or technical grounds. The condonation application and appeal were rejected as time-barred.
Limitation for an appeal under section 61 of the Insolvency and Bankruptcy Code runs from the date of pronouncement of the impugned order, not from the date of upload or the appellant's date of knowledge. The tribunal applied the statutory time-bound appellate scheme and held that the order pronounced on 08.12.2025 triggered limitation from that date. It also held that an alleged technical glitch in the e-filing portal could not justify condonation once the appeal was filed beyond the maximum condonable period of thirty days plus fifteen days, because the tribunal lacked jurisdiction to entertain a delayed appeal on equitable or technical grounds. The condonation application and appeal were rejected as time-barred.
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