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 - The petitioner argued that due to health issues, specifically septic shock, and subsequent challenges in consulting with the relevant authority, they were unable to file the appeal within the prescribed 90-day period. - The High Court directed the Appellate Authority to accept and address the appeal on its merits, provided it was filed within ten days from the receipt of the court's order.
Condonation of delay in filing appeal - The petitioner argued that due to health issues, specifically septic shock, and subsequent challenges in consulting with the relevant authority, they were unable to file the appeal within the prescribed 90-day period. - The High Court directed the Appellate Authority to accept and address the appeal on its merits, provided it was filed within ten days from the receipt of the court's order.
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