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...
Statutory appellate limitation under the BGST Act forms part of the legislative scheme for prompt GST dispute resolution. Writ jurisdiction may be available exceptionally for fundamental-rights violations, breach of natural justice, jurisdictional excess or a vires challenge, but not routinely to revive an expired appellate remedy. The prescribed extension period for a GST appeal constrains the appellate authority, and Article 226 cannot be used to disregard that substantive limitation or condone delay beyond it. An unexplained prolonged delay in approaching the High Court after an appeal is rejected as time-barred undermines the limitation regime; a writ challenge in those circumstances is not maintainable.
Statutory appellate limitation under the BGST Act forms part of the legislative scheme for prompt GST dispute resolution. Writ jurisdiction may be available exceptionally for fundamental-rights violations, breach of natural justice, jurisdictional excess or a vires challenge, but not routinely to revive an expired appellate remedy. The prescribed extension period for a GST appeal constrains the appellate authority, and Article 226 cannot be used to disregard that substantive limitation or condone delay beyond it. An unexplained prolonged delay in approaching the High Court after an appeal is rejected as time-barred undermines the limitation regime; a writ challenge in those circumstances is not maintainable.
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