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...
The High Court held that the petitioner's failure to file an appeal u/s 107 of the GST enactment against an impugned tax payment order rendered the Writ Petition without merit. The Court noted the expiry of the appeal filing deadline and the recovery of the tax amount from the petitioner. The petitioner was granted 30 days to file a statutory appeal in compliance with the law. The writ petition was disposed of accordingly.
The High Court held that the petitioner's failure to file an appeal u/s 107 of the GST enactment against an impugned tax payment order rendered the Writ Petition without merit. The Court noted the expiry of the appeal filing deadline and the recovery of the tax amount from the petitioner. The petitioner was granted 30 days to file a statutory appeal in compliance with the law. The writ petition was disposed of accordingly.
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