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 writ petition challenging tax assessment orders, finding the appeal time-barred under the 2017 Act. The appellate authority correctly rejected the appeal filed beyond the prescribed limitation period, with no power to condone delay beyond one month. Relying on Supreme Court precedent, the HC held that where statutory remedy is foreclosed by limitation, judicial review under Article 226 is impermissible. The petitioner failed to demonstrate jurisdictional error or violation of natural justice principles, resulting in outright dismissal of the petition.
HC dismissed the writ petition challenging tax assessment orders, finding the appeal time-barred under the 2017 Act. The appellate authority correctly rejected the appeal filed beyond the prescribed limitation period, with no power to condone delay beyond one month. Relying on Supreme Court precedent, the HC held that where statutory remedy is foreclosed by limitation, judicial review under Article 226 is impermissible. The petitioner failed to demonstrate jurisdictional error or violation of natural justice principles, resulting in outright dismissal of the petition.
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