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 was initially rejected on the ground of limitation due to the non-availability of a self-attested copy of the order within the stipulated time frame as per Rule 108 of the UPGST/CGST Rules. However, the High Court, relying on the precedent set in the case of Visible Alpha Solutions India Private Limited, held that an appeal cannot be dismissed solely on the ground of limitation for non-filing of a certified copy of the order. Consequently, the impugned order was quashed, and the matter was remanded to the concerned authority for a fresh decision within two months, after hearing all stakeholders and passing a reasoned and speaking order.
The appeal was initially rejected on the ground of limitation due to the non-availability of a self-attested copy of the order within the stipulated time frame as per Rule 108 of the UPGST/CGST Rules. However, the High Court, relying on the precedent set in the case of Visible Alpha Solutions India Private Limited, held that an appeal cannot be dismissed solely on the ground of limitation for non-filing of a certified copy of the order. Consequently, the impugned order was quashed, and the matter was remanded to the concerned authority for a fresh decision within two months, after hearing all stakeholders and passing a reasoned and speaking order.
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