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...
The service tax adjudication deadline is a directory time limit, not an absolute bar, because the statutory phrase "where it is possible to do so" qualifies the period for passing orders. The provision is intended to secure expeditious disposal and curb administrative delay, but it does not invalidate an adjudication passed beyond one year where the delay is justified. Where repeated notices and hearing opportunities were issued and the assessee did not respond until the final notice, the resulting delay was attributable to the assessee, and the assessee could not rely on its own default to challenge the adjudication.
The service tax adjudication deadline is a directory time limit, not an absolute bar, because the statutory phrase "where it is possible to do so" qualifies the period for passing orders. The provision is intended to secure expeditious disposal and curb administrative delay, but it does not invalidate an adjudication passed beyond one year where the delay is justified. Where repeated notices and hearing opportunities were issued and the assessee did not respond until the final notice, the resulting delay was attributable to the assessee, and the assessee could not rely on its own default to challenge the adjudication.
Note: It is a system-generated summary and is for quick reference only.