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 68 days' delay in filing appeal was denied due to lack of sufficient cause. The appellant failed to demonstrate how he was prevented from filing the appeal within the statutory period u/s 421(3) proviso. The court held that even after showing sufficient cause, parties are not entitled to condonation of delay as a matter of right; the court must exercise discretion. The appellant was clearly negligent, being aware of the order before the deadline, and had already pleaded for extension without prejudice to filing an appeal, indicating awareness of the right to appeal. The court found no sufficient cause preventing the appellant from filing within the extended period and dismissed the delay condonation application.
Condonation of 68 days' delay in filing appeal was denied due to lack of sufficient cause. The appellant failed to demonstrate how he was prevented from filing the appeal within the statutory period u/s 421(3) proviso. The court held that even after showing sufficient cause, parties are not entitled to condonation of delay as a matter of right; the court must exercise discretion. The appellant was clearly negligent, being aware of the order before the deadline, and had already pleaded for extension without prejudice to filing an appeal, indicating awareness of the right to appeal. The court found no sufficient cause preventing the appellant from filing within the extended period and dismissed the delay condonation application.
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