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...
HC held that limitation under Section 107 begins to run only from the date the order or decision is communicated to the assessee, not from mere uploading of the impugned order on the GSTN portal; statutory obligation to "communicate" is distinct from "serve" and requires actual imparting or transmission to the recipient, which unilateral portal upload does not satisfy absent proof of communication or receipt. The court clarified that there is no statutory duty on the assessee to access the portal and that section 169's service provisions are separate. The writ petition by the appellant was disposed of accordingly.
HC held that limitation under Section 107 begins to run only from the date the order or decision is communicated to the assessee, not from mere uploading of the impugned order on the GSTN portal; statutory obligation to "communicate" is distinct from "serve" and requires actual imparting or transmission to the recipient, which unilateral portal upload does not satisfy absent proof of communication or receipt. The court clarified that there is no statutory duty on the assessee to access the portal and that section 169's service provisions are separate. The writ petition by the appellant was disposed of accordingly.
Note: It is a system-generated summary and is for quick reference only.