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 order dismissing the appeal due to non-payment of the mandatory pre-deposit amount u/s 35F of the Central Excise Act, 1944 was challenged. The court relied on a previous judgment where it was held that there was no intent to avoid payment of the pre-deposit, and the Revenue Board had provided a facility for making such pre-deposits. Consequently, the court quashed the appellate order and revived the appeal, subject to the petitioner depositing the pre-deposit amount within two weeks, as per their undertaking.
The order dismissing the appeal due to non-payment of the mandatory pre-deposit amount u/s 35F of the Central Excise Act, 1944 was challenged. The court relied on a previous judgment where it was held that there was no intent to avoid payment of the pre-deposit, and the Revenue Board had provided a facility for making such pre-deposits. Consequently, the court quashed the appellate order and revived the appeal, subject to the petitioner depositing the pre-deposit amount within two weeks, as per their undertaking.
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