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 of 1085 days in filing the appeal u/s 260-A - Revenue's appeal - The court found that the appellant failed to provide a valid explanation for the delay of 1085 days in filing the appeal. Despite the previous appeal being declared infructuous, the court held that it had no relevance to the current appeal, as they pertained to different orders. The court cited a precedent to emphasize that negligence in prosecuting the matter cannot be condoned merely because the government is a party. It highlighted the need for plausible and acceptable explanations for delays.
Condonation of delay of 1085 days in filing the appeal u/s 260-A - Revenue's appeal - The court found that the appellant failed to provide a valid explanation for the delay of 1085 days in filing the appeal. Despite the previous appeal being declared infructuous, the court held that it had no relevance to the current appeal, as they pertained to different orders. The court cited a precedent to emphasize that negligence in prosecuting the matter cannot be condoned merely because the government is a party. It highlighted the need for plausible and acceptable explanations for delays.
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