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 Appellate Authority for Advance Ruling (AAAR) considered the condonation of delay in filing an appeal u/s 100(2) of the CGST/TNGST Act, 2017. The appellant, a Tamilnadu Government-owned Electricity Generation and Distribution Utility, sought condonation of a one-day delay in filing the appeal, citing reasons of staff shortage and administrative issues. The AAAR noted that the appeal should have been filed within 30 days of receiving the order, which was on 12.02.2024. The appellant's explanation for the delay was accepted as not deliberate, and the delay of one day was deemed condonable u/s 100(2). The AAAR, empowered u/s 101(1) of the Acts, allowed the condonation, and the appeal will proceed for consideration on merits. The AAAR granted the COD application.
The Appellate Authority for Advance Ruling (AAAR) considered the condonation of delay in filing an appeal u/s 100(2) of the CGST/TNGST Act, 2017. The appellant, a Tamilnadu Government-owned Electricity Generation and Distribution Utility, sought condonation of a one-day delay in filing the appeal, citing reasons of staff shortage and administrative issues. The AAAR noted that the appeal should have been filed within 30 days of receiving the order, which was on 12.02.2024. The appellant's explanation for the delay was accepted as not deliberate, and the delay of one day was deemed condonable u/s 100(2). The AAAR, empowered u/s 101(1) of the Acts, allowed the condonation, and the appeal will proceed for consideration on merits. The AAAR granted the COD application.
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