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...
Time Limitation - Rejection of appeal filed by the petitioner - Physical copies being submitted on 24.04.2023, beyond the condonable period while electronic filing was within the time limit - The Court found that the petitioner substantially complied with the filing requirements by referencing the assessment order already available on the department website while filing the appeal electronically. The Court held that the appeal was filed within time and remitted the matter back to the 1st respondent for registration and decision according to the law and rules. The approach of the 1st respondent in considering the physical filing date was deemed unacceptable, emphasizing that electronic filing is a facilitation for taxpayers.
Time Limitation - Rejection of appeal filed by the petitioner - Physical copies being submitted on 24.04.2023, beyond the condonable period while electronic filing was within the time limit - The Court found that the petitioner substantially complied with the filing requirements by referencing the assessment order already available on the department website while filing the appeal electronically. The Court held that the appeal was filed within time and remitted the matter back to the 1st respondent for registration and decision according to the law and rules. The approach of the 1st respondent in considering the physical filing date was deemed unacceptable, emphasizing that electronic filing is a facilitation for taxpayers.
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