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 allowed the appeal, finding the filing procedurally valid despite delay in certified copy submission. The court determined that online filing with electronic documents constitutes complete submission, and physical certification is not mandatory. Relying on precedent from Chegg India Private Limited, the HC held that technological advancements in filing systems should be interpreted liberally. The subsequent amendment to Rule 108(3) of CGST Rules, 2017 supports retrospective application, thereby validating the appellant's original submission. The court emphasized that technical procedural requirements should not impede substantive hearing of appeals on merits.
HC allowed the appeal, finding the filing procedurally valid despite delay in certified copy submission. The court determined that online filing with electronic documents constitutes complete submission, and physical certification is not mandatory. Relying on precedent from Chegg India Private Limited, the HC held that technological advancements in filing systems should be interpreted liberally. The subsequent amendment to Rule 108(3) of CGST Rules, 2017 supports retrospective application, thereby validating the appellant's original submission. The court emphasized that technical procedural requirements should not impede substantive hearing of appeals on merits.
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