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 dismissed the appeal concerning condonation of delay in filing second appeal regarding misdeclaration of imported Brass Ceramic Cartridges. The appellant failed to demonstrate due diligence in verifying the Commissioner (Appeals) order status. Despite proper service of hearing notice to both appellant and counsel, and counsel's attendance at hearing, appellant neglected to provide alternative address for order service. The Department fulfilled procedural obligations by sending order to available address. Court held appellant's inaction and counsel's failure to communicate constituted negligence. The CESTAT's order upholding dismissal was affirmed, as delay in filing was attributable to appellant's lack of vigilance rather than departmental oversight.
HC dismissed the appeal concerning condonation of delay in filing second appeal regarding misdeclaration of imported Brass Ceramic Cartridges. The appellant failed to demonstrate due diligence in verifying the Commissioner (Appeals) order status. Despite proper service of hearing notice to both appellant and counsel, and counsel's attendance at hearing, appellant neglected to provide alternative address for order service. The Department fulfilled procedural obligations by sending order to available address. Court held appellant's inaction and counsel's failure to communicate constituted negligence. The CESTAT's order upholding dismissal was affirmed, as delay in filing was attributable to appellant's lack of vigilance rather than departmental oversight.
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