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...
Alternative appellate remedy under GST was treated as the proper course where input tax credit orders were challenged for alleged irregular availment due to belated GSTR filings. The High Court declined to examine the writ petitions on merits and relegated the petitioner to the statutory appellate remedy. It granted liberty to file appeals within two weeks with pre-deposit and delay condonation applications, allowed all legal and factual grounds including later rectification contentions, and left delay to be considered by the appellate authority before any decision on merits.
Alternative appellate remedy under GST was treated as the proper course where input tax credit orders were challenged for alleged irregular availment due to belated GSTR filings. The High Court declined to examine the writ petitions on merits and relegated the petitioner to the statutory appellate remedy. It granted liberty to file appeals within two weeks with pre-deposit and delay condonation applications, allowed all legal and factual grounds including later rectification contentions, and left delay to be considered by the appellate authority before any decision on merits.
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