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 appeal limitation does not begin merely because an order-in-original is uploaded on the common portal without valid communication to the assessee in the stated circumstances. Although the Appellate Authority remains bound by the statutory limitation under the RGST/CGST Act, delay may be condoned where the assessee could not file the appeal for reasons beyond its control and refusal of merits review would cause grave prejudice. The time-bar dismissal was set aside and the statutory appeal restored for merits determination, subject to the directed deposit of outstanding tax.
GST appeal limitation does not begin merely because an order-in-original is uploaded on the common portal without valid communication to the assessee in the stated circumstances. Although the Appellate Authority remains bound by the statutory limitation under the RGST/CGST Act, delay may be condoned where the assessee could not file the appeal for reasons beyond its control and refusal of merits review would cause grave prejudice. The time-bar dismissal was set aside and the statutory appeal restored for merits determination, subject to the directed deposit of outstanding tax.
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