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 overturned dismissal of tax appeal that was rejected due to two-day filing delay. Appeal was filed on 90th day from email communication dated 22.12.2023 of original order dated 20.12.2023. Under Section 107 of KGST Act 2017, three-month appeal period runs from order date or communication date. Appellant had filed rectification application with delay condonation request supported by affidavit within condonable period. Second respondent failed to judiciously exercise powers under Section 107(2) to consider delay condonation. Court directed appeal to be heard on merits, finding technical dismissal unjustified.
HC overturned dismissal of tax appeal that was rejected due to two-day filing delay. Appeal was filed on 90th day from email communication dated 22.12.2023 of original order dated 20.12.2023. Under Section 107 of KGST Act 2017, three-month appeal period runs from order date or communication date. Appellant had filed rectification application with delay condonation request supported by affidavit within condonable period. Second respondent failed to judiciously exercise powers under Section 107(2) to consider delay condonation. Court directed appeal to be heard on merits, finding technical dismissal unjustified.
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