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...
For e-filed appeals under Section 61 of the IBC, limitation is computed from the date of e-filing, in line with the NCLAT's 24.12.2022 directions issued under the NCLAT Rules, 2016. The Tribunal rejected reliance on Delhi High Court e-filing rules because no material showed they applied to NCLAT. It applied the Supreme Court's view that a statutory day runs for 24 hours from midnight, so filing after office hours does not shift the filing date to the next working day. An appeal e-filed at 9.00 p.m. on the 45th day was therefore within the condonable period, and the 15-day delay was condoned.
For e-filed appeals under Section 61 of the IBC, limitation is computed from the date of e-filing, in line with the NCLAT's 24.12.2022 directions issued under the NCLAT Rules, 2016. The Tribunal rejected reliance on Delhi High Court e-filing rules because no material showed they applied to NCLAT. It applied the Supreme Court's view that a statutory day runs for 24 hours from midnight, so filing after office hours does not shift the filing date to the next working day. An appeal e-filed at 9.00 p.m. on the 45th day was therefore within the condonable period, and the 15-day delay was condoned.
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