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...
Delay in filing the appeal - Time Limitation - petition delayed for almost one year - extension of period for filing a delayed appeal - The Court held that when a statute provides a specific period within which an appeal must be filed, neither the Appellate Authority nor the High Court has the power to condone delays beyond that period. - It noted that the Notification No. 53 of 2023 extended the time for filing appeals under certain conditions, including the payment of specified amounts. - The Court directed the petitioner to file an appeal satisfying the conditions outlined in the notification before the stipulated time. It clarified that if the appeal met the conditions, it would be taken up and considered on its merits.
Delay in filing the appeal - Time Limitation - petition delayed for almost one year - extension of period for filing a delayed appeal - The Court held that when a statute provides a specific period within which an appeal must be filed, neither the Appellate Authority nor the High Court has the power to condone delays beyond that period. - It noted that the Notification No. 53 of 2023 extended the time for filing appeals under certain conditions, including the payment of specified amounts. - The Court directed the petitioner to file an appeal satisfying the conditions outlined in the notification before the stipulated time. It clarified that if the appeal met the conditions, it would be taken up and considered on its merits.
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