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...
Writ jurisdiction was declined where a statutory appellate remedy under GST was available. The petitioner was permitted to file the appeal within the time granted, along with a delay condonation application and the statutory pre-deposit, and was allowed to urge all factual and legal grounds before the appellate authority. The appellate authority was directed to consider the reasons for delay and, if satisfied, decide the appeal on merits. Coercive steps pursuant to the impugned garnishee notices were stayed only for the limited period granted to file the appeal.
Writ jurisdiction was declined where a statutory appellate remedy under GST was available. The petitioner was permitted to file the appeal within the time granted, along with a delay condonation application and the statutory pre-deposit, and was allowed to urge all factual and legal grounds before the appellate authority. The appellate authority was directed to consider the reasons for delay and, if satisfied, decide the appeal on merits. Coercive steps pursuant to the impugned garnishee notices were stayed only for the limited period granted to file the appeal.
Note: It is a system-generated summary and is for quick reference only.