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...
Court considered condonation of delay in filing appeal, mismatch between petitioner's GSTR 1 and GSTR 3B returns. Held appeal was rejected as filed 29 days beyond condonable period u/s 107 of GST statutes. Petitioner stated inability to file appeal timely due to order being uploaded on portal, known on specific date. Considering facts and circumstances, HC directed appellate authority to consider and dispose appeal on merits, subject to petitioner re-presenting appeal within 10 days. Petition disposed by way of remand to appellate authority.
Court considered condonation of delay in filing appeal, mismatch between petitioner's GSTR 1 and GSTR 3B returns. Held appeal was rejected as filed 29 days beyond condonable period u/s 107 of GST statutes. Petitioner stated inability to file appeal timely due to order being uploaded on portal, known on specific date. Considering facts and circumstances, HC directed appellate authority to consider and dispose appeal on merits, subject to petitioner re-presenting appeal within 10 days. Petition disposed by way of remand to appellate authority.
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