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...
Restoration of the statutory appeal - The CESTAT had dismissed the appeal due to the petitioner's non-representation at a hearing and the failure to inform about pre-deposit compliance. The petitioner later sought restoration, asserting compliance, albeit with a delay. - The High Court, noting the compliance with the pre-deposit requirement and the larger interest of justice, directed the restoration of the appeal on the CESTAT's board, subject to the petitioner depositing costs of INR 2 lakhs within two weeks.
Restoration of the statutory appeal - The CESTAT had dismissed the appeal due to the petitioner's non-representation at a hearing and the failure to inform about pre-deposit compliance. The petitioner later sought restoration, asserting compliance, albeit with a delay. - The High Court, noting the compliance with the pre-deposit requirement and the larger interest of justice, directed the restoration of the appeal on the CESTAT's board, subject to the petitioner depositing costs of INR 2 lakhs within two weeks.
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