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...
The HC addressed systemic delays in appeals at the National Faceless Appeal Centre (NFAC), acknowledging the significant backlog of pending statutory appeals. While recognizing the need for expeditious resolution, the court refrained from issuing specific directives. The HC expressed confidence that NFAC would implement internal remedial measures to accelerate appeal disposals. Ultimately, the petition was disposed of without mandating explicit procedural interventions, leaving NFAC to independently address its administrative challenges and reduce pendency through its own strategic mechanisms.
The HC addressed systemic delays in appeals at the National Faceless Appeal Centre (NFAC), acknowledging the significant backlog of pending statutory appeals. While recognizing the need for expeditious resolution, the court refrained from issuing specific directives. The HC expressed confidence that NFAC would implement internal remedial measures to accelerate appeal disposals. Ultimately, the petition was disposed of without mandating explicit procedural interventions, leaving NFAC to independently address its administrative challenges and reduce pendency through its own strategic mechanisms.
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