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...
GST tax determination for April 2019 to March 2020 was held time-barred because the order-in-original was passed and uploaded after the statutory cut-off of 31.08.2024. The Department's explanation that the officer was handling a heavy workload did not cure the defect, since limitation went to the root of jurisdiction to impose tax liability. The appellate authority also erred in overlooking this jurisdictional infirmity and dismissing the appeal on delay. The original adjudication and appellate orders were set aside as unsustainable in law.
GST tax determination for April 2019 to March 2020 was held time-barred because the order-in-original was passed and uploaded after the statutory cut-off of 31.08.2024. The Department's explanation that the officer was handling a heavy workload did not cure the defect, since limitation went to the root of jurisdiction to impose tax liability. The appellate authority also erred in overlooking this jurisdictional infirmity and dismissing the appeal on delay. The original adjudication and appellate orders were set aside as unsustainable in law.
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