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 condoned a 67-day delay in filing the appeal against the impugned assessment order arising from mismatched Input Tax Credit claims and excess ITC. The petitioner's pursuit of a rectification application was deemed a sufficient cause for the delay. Consequently, the 2nd respondent/Appellate Authority was directed to admit the appeal without raising limitation objections, subject to the petitioner depositing 15% of the disputed tax demand-comprising a 5% amount agreed upon and a 10% statutory pre-deposit-within two weeks. The petition was disposed of accordingly.
The HC condoned a 67-day delay in filing the appeal against the impugned assessment order arising from mismatched Input Tax Credit claims and excess ITC. The petitioner's pursuit of a rectification application was deemed a sufficient cause for the delay. Consequently, the 2nd respondent/Appellate Authority was directed to admit the appeal without raising limitation objections, subject to the petitioner depositing 15% of the disputed tax demand-comprising a 5% amount agreed upon and a 10% statutory pre-deposit-within two weeks. The petition was disposed of accordingly.
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