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 held that electronic service of notices under Central Excise Act 1944 is permissible through application of CGST Act provisions. Reading Sections 142(8)(a) and 169(1)(c) of CGST Act together enables electronic service modes for existing laws including 1944 Act, despite Section 37C being silent on email service. Court rejected petitioner's argument against electronic notice validity and distinguished prior CESTAT precedent as inapplicable. Directed petitioner to pursue statutory appeal remedy with delay condonation application, excluding court proceedings duration from limitation period. Time spent before court would not count towards appeal limitation. Petition disposed of with directions to appellate authority to consider appeal per law.
HC held that electronic service of notices under Central Excise Act 1944 is permissible through application of CGST Act provisions. Reading Sections 142(8)(a) and 169(1)(c) of CGST Act together enables electronic service modes for existing laws including 1944 Act, despite Section 37C being silent on email service. Court rejected petitioner's argument against electronic notice validity and distinguished prior CESTAT precedent as inapplicable. Directed petitioner to pursue statutory appeal remedy with delay condonation application, excluding court proceedings duration from limitation period. Time spent before court would not count towards appeal limitation. Petition disposed of with directions to appellate authority to consider appeal per law.
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