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...
Writ petition disposed of directing petitioner to file appeal against order manually within one week from receipt of certified copy of judgment as per proviso to sub-rule (3) of Rule 108 of CGST/SGST Rules, despite inability to file appeal online due to non-uploading of order on portal. Appeal to be treated as filed in time and disposed of by Appellate Authority in accordance with law after granting opportunity of hearing to petitioner.
Writ petition disposed of directing petitioner to file appeal against order manually within one week from receipt of certified copy of judgment as per proviso to sub-rule (3) of Rule 108 of CGST/SGST Rules, despite inability to file appeal online due to non-uploading of order on portal. Appeal to be treated as filed in time and disposed of by Appellate Authority in accordance with law after granting opportunity of hearing to petitioner.
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