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...
Petitioner, a central public sector undertaking, challenged rejection of its appeal by appellate authority solely on grounds of delay without considering merits. HC quashed appellate order as perverse for mechanically dismissing condonation application without adequately considering petitioner's lack of knowledge about impugned order's issuance. Relying on precedent, HC condoned delay, exercising power u/s 107(4) of the Act, rendering remand to appellate authority unnecessary. Petition disposed of.
Petitioner, a central public sector undertaking, challenged rejection of its appeal by appellate authority solely on grounds of delay without considering merits. HC quashed appellate order as perverse for mechanically dismissing condonation application without adequately considering petitioner's lack of knowledge about impugned order's issuance. Relying on precedent, HC condoned delay, exercising power u/s 107(4) of the Act, rendering remand to appellate authority unnecessary. Petition disposed of.
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