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 51-day delay in filing the appeal, finding the petitioner's reasons-time taken to gather supporting documents, reconcile records, and obtain legal advice-genuine and sufficient. The appeal was restored before the 2nd respondent subject to the petitioner paying Rs. 5,000 to the specified government medical institution within two weeks of receiving the order. The petition was disposed of accordingly.
The HC condoned a 51-day delay in filing the appeal, finding the petitioner's reasons-time taken to gather supporting documents, reconcile records, and obtain legal advice-genuine and sufficient. The appeal was restored before the 2nd respondent subject to the petitioner paying Rs. 5,000 to the specified government medical institution within two weeks of receiving the order. The petition was disposed of accordingly.
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