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...
Tribunal jurisdiction to condone delay beyond the statutory cap under section 107(4) of the CGST Act is identified as the central issue. The Special Bench directed the Registry to obtain and place details of appeals involving the identical question and listed the matter for hearing. The text records no determination on whether delay beyond the statutory limit may be condoned.
Tribunal jurisdiction to condone delay beyond the statutory cap under section 107(4) of the CGST Act is identified as the central issue. The Special Bench directed the Registry to obtain and place details of appeals involving the identical question and listed the matter for hearing. The text records no determination on whether delay beyond the statutory limit may be condoned.
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