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 petition was dismissed due to the appeal being filed beyond the limitation period without a proper explanation for the delay. The High Court held that it cannot condone the delay under extraordinary jurisdiction when the petitioners failed to provide valid grounds. The Supreme Court precedent in Singh Enterprises case affirmed that there is no power to condone delay after the expiry of the 30-day period. Consequently, no interference was warranted in the impugned orders canceling the GST registration.
The petition was dismissed due to the appeal being filed beyond the limitation period without a proper explanation for the delay. The High Court held that it cannot condone the delay under extraordinary jurisdiction when the petitioners failed to provide valid grounds. The Supreme Court precedent in Singh Enterprises case affirmed that there is no power to condone delay after the expiry of the 30-day period. Consequently, no interference was warranted in the impugned orders canceling the GST registration.
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