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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The HC followed its earlier decision in an identical matter and held that delay in filing the statutory appeal could be condoned where the appellate authority had no power to condone delay and the writ remedy was pursued bona fide. The writ petition was allowed on the same terms as in Shobhalal, the original and appellate orders were quashed, and the appellate authority was directed to hear and decide the already filed appeal on merits in accordance with law, subject to compliance with the statutory deposit and other dues directed by the Court.
The HC followed its earlier decision in an identical matter and held that delay in filing the statutory appeal could be condoned where the appellate authority had no power to condone delay and the writ remedy was pursued bona fide. The writ petition was allowed on the same terms as in Shobhalal, the original and appellate orders were quashed, and the appellate authority was directed to hear and decide the already filed appeal on merits in accordance with law, subject to compliance with the statutory deposit and other dues directed by the Court.
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