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 petition challenging GST order validity based on unsigned Form DRC-07 summary and time-barred filing. Court held that petitioner failed to pursue available statutory appeal remedies within prescribed limitation period. Following SC precedent in Glaxo Smith Kline, HC found petition non-maintainable as entertaining it would contravene statutory scheme. Original order contained proper signature and was issued within extended limitation period until 30.04.2024. Absence of signature on DRC-07, being merely a summary document, caused no prejudice. Petitioner retains right to pursue statutory remedies if permissible under law.
HC dismissed petition challenging GST order validity based on unsigned Form DRC-07 summary and time-barred filing. Court held that petitioner failed to pursue available statutory appeal remedies within prescribed limitation period. Following SC precedent in Glaxo Smith Kline, HC found petition non-maintainable as entertaining it would contravene statutory scheme. Original order contained proper signature and was issued within extended limitation period until 30.04.2024. Absence of signature on DRC-07, being merely a summary document, caused no prejudice. Petitioner retains right to pursue statutory remedies if permissible under law.
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