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...
A review order restoring pending appeals was treated as a consequence of the liberty expressly reserved in the earlier appellate order and of the Supreme Court's recall of the binding precedent. The HC held that, where the Tribunal allowed review and restored the appeals in terms of that liberty, the appellants could not challenge the restoration by disputing review power or limitation. It further held that an order granting review and reviving the main appeal is interlocutory and not independently appealable, because the CPC applies to the Tribunal and the bar in Order 47 Rule 7 CPC operates against an appeal from such a review order. The appeals were dismissed as not maintainable.
A review order restoring pending appeals was treated as a consequence of the liberty expressly reserved in the earlier appellate order and of the Supreme Court's recall of the binding precedent. The HC held that, where the Tribunal allowed review and restored the appeals in terms of that liberty, the appellants could not challenge the restoration by disputing review power or limitation. It further held that an order granting review and reviving the main appeal is interlocutory and not independently appealable, because the CPC applies to the Tribunal and the bar in Order 47 Rule 7 CPC operates against an appeal from such a review order. The appeals were dismissed as not maintainable.
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