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, noting precedent favoring dismissal, granted conditional relief to the petitioner in a tax dispute under the TNVAT/GST transition, holding that the petitioner may file an appeal before the Appellate Authority, Joint Commissioner (Appeals) (JC(A)), BiBikulam, Madurai, within 15 days of receipt of this order. The petition is disposed of on the condition that the petitioner deposits Rs.35,00,000 within 15 days; failure to comply will warrant dismissal. The JC(A), not originally a party, is suo motu impleaded as the fourth respondent. The order preserves the Government's revenue interest while permitting adjudication on the merits by the statutory appellate forum.
The HC, noting precedent favoring dismissal, granted conditional relief to the petitioner in a tax dispute under the TNVAT/GST transition, holding that the petitioner may file an appeal before the Appellate Authority, Joint Commissioner (Appeals) (JC(A)), BiBikulam, Madurai, within 15 days of receipt of this order. The petition is disposed of on the condition that the petitioner deposits Rs.35,00,000 within 15 days; failure to comply will warrant dismissal. The JC(A), not originally a party, is suo motu impleaded as the fourth respondent. The order preserves the Government's revenue interest while permitting adjudication on the merits by the statutory appellate forum.
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