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 exercised its discretionary jurisdiction to condone delay in filing the appeal, finding the petitioner's reasons for delay bona fide, and thus set aside both the impugned assessment order issued by the first respondent and the rejection of the appeal by the second respondent. The Court granted the petitioner one opportunity to prosecute the appeal before the Appellate Authority subject to conditions: the petitioner must remit an additional 5% of the disputed tax in supplement to the 10% pre-deposit already paid at the time of filing, and such further deposit must be made within two weeks of receipt of this order. The writ petition is disposed of accordingly.
The HC exercised its discretionary jurisdiction to condone delay in filing the appeal, finding the petitioner's reasons for delay bona fide, and thus set aside both the impugned assessment order issued by the first respondent and the rejection of the appeal by the second respondent. The Court granted the petitioner one opportunity to prosecute the appeal before the Appellate Authority subject to conditions: the petitioner must remit an additional 5% of the disputed tax in supplement to the 10% pre-deposit already paid at the time of filing, and such further deposit must be made within two weeks of receipt of this order. The writ petition is disposed of accordingly.
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