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 petition challenging the order refusing to entertain an appeal, holding the appeal was instituted beyond the maximum condonable period and no non-communication of the Order-in-Original was established. The court found the reasons for delay insufficient and concluded the appeal exceeded the statutory extended limitation period, precluding further condonation. Exercising jurisdiction under Article 226 could not subvert the legislative scheme embodied in the statutory limitation framework (including the prescribed condonable period), and the petitioner's arguable merits could not cure the jurisdictional bar. Consequently, the petition was dismissed and the impugned order declining to admit the appeal was upheld.
The HC dismissed the petition challenging the order refusing to entertain an appeal, holding the appeal was instituted beyond the maximum condonable period and no non-communication of the Order-in-Original was established. The court found the reasons for delay insufficient and concluded the appeal exceeded the statutory extended limitation period, precluding further condonation. Exercising jurisdiction under Article 226 could not subvert the legislative scheme embodied in the statutory limitation framework (including the prescribed condonable period), and the petitioner's arguable merits could not cure the jurisdictional bar. Consequently, the petition was dismissed and the impugned order declining to admit the appeal was upheld.
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