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...
Where a customs adjudication order is challenged after expiry of the statutory appeal period, writ jurisdiction should not be invoked when an efficacious appellate remedy existed and was not availed within the prescribed or condonable time. The natural justice exception did not assist the petitioners because they showed no compelling reason for missing the appeal, did not seek condonation, and did not explain the delay in approaching the appellate forum or the writ court. The writ petitions were therefore held not maintainable and rejected.
Where a customs adjudication order is challenged after expiry of the statutory appeal period, writ jurisdiction should not be invoked when an efficacious appellate remedy existed and was not availed within the prescribed or condonable time. The natural justice exception did not assist the petitioners because they showed no compelling reason for missing the appeal, did not seek condonation, and did not explain the delay in approaching the appellate forum or the writ court. The writ petitions were therefore held not maintainable and rejected.
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