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 upheld the dismissal of the appeal filed three years and twenty days beyond the prescribed limitation period, affirming that the appellate authority's power to condone delay is strictly limited to thirty days. The court relied on established precedents interpreting analogous statutory provisions, emphasizing that no residual discretion exists to extend limitation beyond the specified period under the relevant Acts. Consequently, the writ petition challenging the order was dismissed, reinforcing the principle that courts and tribunals cannot entertain appeals filed beyond the statutory time frame except within narrowly prescribed limits.
The HC upheld the dismissal of the appeal filed three years and twenty days beyond the prescribed limitation period, affirming that the appellate authority's power to condone delay is strictly limited to thirty days. The court relied on established precedents interpreting analogous statutory provisions, emphasizing that no residual discretion exists to extend limitation beyond the specified period under the relevant Acts. Consequently, the writ petition challenging the order was dismissed, reinforcing the principle that courts and tribunals cannot entertain appeals filed beyond the statutory time frame except within narrowly prescribed limits.
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