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 set aside the impugned order dismissing the appellant's appeal for non-compliance with the pre-deposit requirement and non-production of Electronic Cash/credit ledger or Form GST DRC-03 and self-certified copy of the order. The court found an eight-day delay in filing but noted the Appellate Authority's power to condone up to 30 days and that the appellant demonstrated practical difficulties and tendered the challan; the Authority erred in dismissing without affording condonation. The petition is allowed by remand: if the appellant files a self-certified copy of the impugned order, an application for condonation and necessary deposit within one week of receipt of the certified copy, the Appellate Authority shall reconsider the appeal in accordance with law.
The HC set aside the impugned order dismissing the appellant's appeal for non-compliance with the pre-deposit requirement and non-production of Electronic Cash/credit ledger or Form GST DRC-03 and self-certified copy of the order. The court found an eight-day delay in filing but noted the Appellate Authority's power to condone up to 30 days and that the appellant demonstrated practical difficulties and tendered the challan; the Authority erred in dismissing without affording condonation. The petition is allowed by remand: if the appellant files a self-certified copy of the impugned order, an application for condonation and necessary deposit within one week of receipt of the certified copy, the Appellate Authority shall reconsider the appeal in accordance with law.
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