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...
Condonation of delay in a GST appeal was granted despite filing beyond the period under section 107 because factual questions required appellate adjudication. Applying the approach in Simplex Infrastructures Ltd. in the peculiar circumstances, the High Court held that the taxpayer should receive a further opportunity to pursue the statutory appeal. The time-bar dismissal and consequential rectification order were quashed, and the appeal was restored for decision on merits after a proper hearing. All substantive contentions remained open.
Condonation of delay in a GST appeal was granted despite filing beyond the period under section 107 because factual questions required appellate adjudication. Applying the approach in Simplex Infrastructures Ltd. in the peculiar circumstances, the High Court held that the taxpayer should receive a further opportunity to pursue the statutory appeal. The time-bar dismissal and consequential rectification order were quashed, and the appeal was restored for decision on merits after a proper hearing. All substantive contentions remained open.
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