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...
Condonation of delay in a statutory appeal against confiscation of foreign currency was allowed where the delay was not found to be exorbitant or inordinate and refusal would have left the petitioner remediless. Although the appellate authority's power to condone delay was limited and the supporting explanation was not elaborate, the Court held that the right of appeal should not be shut out on the facts of the case. The dismissal of the time-barred appeal was set aside, costs were imposed, and the appellate authority was directed to hear and decide the matter on merits, without treating the decision as a binding precedent.
Condonation of delay in a statutory appeal against confiscation of foreign currency was allowed where the delay was not found to be exorbitant or inordinate and refusal would have left the petitioner remediless. Although the appellate authority's power to condone delay was limited and the supporting explanation was not elaborate, the Court held that the right of appeal should not be shut out on the facts of the case. The dismissal of the time-barred appeal was set aside, costs were imposed, and the appellate authority was directed to hear and decide the matter on merits, without treating the decision as a binding precedent.
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