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 filing appeal - Applicability of limitation act - the appellate authority did have the power to condone the delay in filing an appeal beyond the prescribed period under Section 107 of the Act of 2017. This decision was based on the principle that the Act of 1963’s provisions, particularly Section 29(2), were not expressly or impliedly excluded by Section 107 of the Act of 2017. Consequently, the appellate authority must consider the appeal on its merits, giving the petitioner an opportunity for a hearing. The court held that the petitioner's health issues constituted sufficient cause for the delay in filing the appeal. - HC
Condonation of delay in filing appeal - Applicability of limitation act - the appellate authority did have the power to condone the delay in filing an appeal beyond the prescribed period under Section 107 of the Act of 2017. This decision was based on the principle that the Act of 1963’s provisions, particularly Section 29(2), were not expressly or impliedly excluded by Section 107 of the Act of 2017. Consequently, the appellate authority must consider the appeal on its merits, giving the petitioner an opportunity for a hearing. The court held that the petitioner's health issues constituted sufficient cause for the delay in filing the appeal. - HC
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