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 High Court dismissed the petition challenging the cancellation of the petitioner's GST registration. The appeal against the cancellation order was filed beyond the prescribed limitation period. The Court held that it cannot condone the delay in filing the appeal under its extraordinary jurisdiction, as the Supreme Court has ruled that there is no power to condone the delay after the expiry of the statutory period for filing appeals under the relevant law. The Court observed that while it has wide jurisdiction under Article 226 of the Constitution, it cannot disregard the substantive provisions of the statute and pass orders contrary to the mechanism prescribed therein. Consequently, no interference was warranted in the impugned orders, and the petition was dismissed.
The High Court dismissed the petition challenging the cancellation of the petitioner's GST registration. The appeal against the cancellation order was filed beyond the prescribed limitation period. The Court held that it cannot condone the delay in filing the appeal under its extraordinary jurisdiction, as the Supreme Court has ruled that there is no power to condone the delay after the expiry of the statutory period for filing appeals under the relevant law. The Court observed that while it has wide jurisdiction under Article 226 of the Constitution, it cannot disregard the substantive provisions of the statute and pass orders contrary to the mechanism prescribed therein. Consequently, no interference was warranted in the impugned orders, and the petition was dismissed.
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