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 allowed the petition, quashing the appellate authority's order that rejected the petitioner's appeal for failure to pay the required pre-deposit in cash, and restored the appeal on file. The court held that payment from the electronic credit ledger satisfies the pre-deposit requirement under Section 107(6)(b) of the CGST Act and that electronic transfer must be treated as valid tender for pre-deposit purposes. Having found the appellate authority's refusal unsustainable in light of a directly analogous HC decision, the court set aside the impugned order and directed reinstatement of the petitioner's appeal, granting the petition.
The HC allowed the petition, quashing the appellate authority's order that rejected the petitioner's appeal for failure to pay the required pre-deposit in cash, and restored the appeal on file. The court held that payment from the electronic credit ledger satisfies the pre-deposit requirement under Section 107(6)(b) of the CGST Act and that electronic transfer must be treated as valid tender for pre-deposit purposes. Having found the appellate authority's refusal unsustainable in light of a directly analogous HC decision, the court set aside the impugned order and directed reinstatement of the petitioner's appeal, granting the petition.
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