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...
HC condoned 142-day delay in filing GST appeal where appellant demonstrated reasonable cause due to belated service of demand notice. While notice was uploaded on GST portal, physical copy was only served on 16.04.2024. Court determined delayed physical service constituted sufficient grounds for condonation, setting aside appellate authority's original order rejecting appeal. Delay condoned under principles of reasonable cause and procedural fairness, acknowledging distinction between portal upload and actual service of notice. Original appellate order vacated, allowing appellant to proceed with substantive appeal on merits.
HC condoned 142-day delay in filing GST appeal where appellant demonstrated reasonable cause due to belated service of demand notice. While notice was uploaded on GST portal, physical copy was only served on 16.04.2024. Court determined delayed physical service constituted sufficient grounds for condonation, setting aside appellate authority's original order rejecting appeal. Delay condoned under principles of reasonable cause and procedural fairness, acknowledging distinction between portal upload and actual service of notice. Original appellate order vacated, allowing appellant to proceed with substantive appeal on merits.
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