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...
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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 petitions, holding the appeals were instituted within the extended limitation and therefore not time-barred. The court set aside the impugned orders and restored the petitioners' appeals to the appellate authority for fresh adjudication on merits in accordance with law. The HC relied on a comparable Division Bench decision of Patna HC which observed that the notification relied upon predated the purported cut-off, undermining any rationale for denying filing on the ground of limitation. Consequently, the petitions were allowed and the matter remitted for reconsideration by the appellate authority.
The HC allowed the petitions, holding the appeals were instituted within the extended limitation and therefore not time-barred. The court set aside the impugned orders and restored the petitioners' appeals to the appellate authority for fresh adjudication on merits in accordance with law. The HC relied on a comparable Division Bench decision of Patna HC which observed that the notification relied upon predated the purported cut-off, undermining any rationale for denying filing on the ground of limitation. Consequently, the petitions were allowed and the matter remitted for reconsideration by the appellate authority.
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