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...
Maintainability of appeal - appeal dismissed on the ground of time limitation - non-submission of the certified copy. - Despite discrepancies raised by the respondent regarding the existence of the appeal in the online portal, the court found merit in the petitioner's submissions, affirming the timely filing of the appeal. Moreover, the court dismissed the notion that the appeal was time-barred due to the petitioner's failure to submit a certified copy of the original order, as evidence suggested otherwise. Consequently, the court set aside the impugned order and remitted the matter to the Appellate Authority for consideration on its merits in accordance with the law.
Maintainability of appeal - appeal dismissed on the ground of time limitation - non-submission of the certified copy. - Despite discrepancies raised by the respondent regarding the existence of the appeal in the online portal, the court found merit in the petitioner's submissions, affirming the timely filing of the appeal. Moreover, the court dismissed the notion that the appeal was time-barred due to the petitioner's failure to submit a certified copy of the original order, as evidence suggested otherwise. Consequently, the court set aside the impugned order and remitted the matter to the Appellate Authority for consideration on its merits in accordance with the law.
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