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 appeal filed by the petitioner u/s 107 of the West Bengal/Central Goods and Services Tax Act, 2017 was rejected. The petitioner argued lack of opportunity to respond to Show Cause Notice (SCN) online. The court found the delay in filing the appeal justified due to lack of knowledge of the order and allowed condonation beyond the prescribed period. The appellate authority's decision was deemed flawed and set aside based on precedent allowing for condonation of delay. The matter was not remanded on the issue of delay, and the appellate authority was directed to hear and decide the appeal within eight weeks.
The appeal filed by the petitioner u/s 107 of the West Bengal/Central Goods and Services Tax Act, 2017 was rejected. The petitioner argued lack of opportunity to respond to Show Cause Notice (SCN) online. The court found the delay in filing the appeal justified due to lack of knowledge of the order and allowed condonation beyond the prescribed period. The appellate authority's decision was deemed flawed and set aside based on precedent allowing for condonation of delay. The matter was not remanded on the issue of delay, and the appellate authority was directed to hear and decide the appeal within eight weeks.
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