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...
Condonation of delay in filing appeal is governed by Section 5 of Limitation Act. When special statute provides period for initiating proceeding and authority to condone delay without specifying time limit, Section 5 applies. Central Board of Indirect Taxes and Customs extended time for filing appeal against certain orders under BGST Act beyond statutory period. Extraordinary jurisdiction under Article 226 cannot be invoked when alternate remedies available and assessee failed to avail them diligently within stipulated time.
Condonation of delay in filing appeal is governed by Section 5 of Limitation Act. When special statute provides period for initiating proceeding and authority to condone delay without specifying time limit, Section 5 applies. Central Board of Indirect Taxes and Customs extended time for filing appeal against certain orders under BGST Act beyond statutory period. Extraordinary jurisdiction under Article 226 cannot be invoked when alternate remedies available and assessee failed to avail them diligently within stipulated time.
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