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 a 35-day delay in filing GST appeal, emphasizing that procedural delays should not override substantive justice. The petitioner had demonstrated compliance by depositing 10% of tax liability and making additional payments toward disputed amount. Court found strict application of GST Act's limitation provisions unwarranted given circumstances. Matter remanded to second respondent for fresh consideration on merits, directing full examination of facts and circumstances. Decision underscores judicial preference for substantive resolution over procedural dismissal in tax matters where appellant shows good faith compliance efforts.
HC condoned a 35-day delay in filing GST appeal, emphasizing that procedural delays should not override substantive justice. The petitioner had demonstrated compliance by depositing 10% of tax liability and making additional payments toward disputed amount. Court found strict application of GST Act's limitation provisions unwarranted given circumstances. Matter remanded to second respondent for fresh consideration on merits, directing full examination of facts and circumstances. Decision underscores judicial preference for substantive resolution over procedural dismissal in tax matters where appellant shows good faith compliance efforts.
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