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 dismissed the writ petition on grounds of inordinate delay exceeding three years from the assessment order. The petitioner conceded receipt of the show cause notice via the common GST portal, confirming knowledge of proceedings under Section 74 of the GST Act. The Court emphasized that under Section 107, the appellate authority may condone delay only up to thirty days beyond the prescribed period. Since the petition was filed well beyond this condonable period, it was held to be non-maintainable. Furthermore, service of notice through the GST portal was deemed valid under Section 169 of the GST Act, negating any claim of non-service. Consequently, the writ petition was dismissed for being barred by delay and failure to comply with statutory timelines.
The HC dismissed the writ petition on grounds of inordinate delay exceeding three years from the assessment order. The petitioner conceded receipt of the show cause notice via the common GST portal, confirming knowledge of proceedings under Section 74 of the GST Act. The Court emphasized that under Section 107, the appellate authority may condone delay only up to thirty days beyond the prescribed period. Since the petition was filed well beyond this condonable period, it was held to be non-maintainable. Furthermore, service of notice through the GST portal was deemed valid under Section 169 of the GST Act, negating any claim of non-service. Consequently, the writ petition was dismissed for being barred by delay and failure to comply with statutory timelines.
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