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 tribunal directed mandatory electronic filing and hearing of appeals on the government portal and prescribed staggered filing windows to avoid portal capacity and concurrency issues, allocating specific filing periods based on when first-instance appeals or revision notices were originally filed; the staggered schedule runs from 24.09.2025 to various deadlines not later than 30.06.2026. The measure invokes procedural rule powers to manage system load, applies to appeals under the CGST Act sections covering first appeals and revisions, and preserves the tribunal's substantive powers under the Act.
The tribunal directed mandatory electronic filing and hearing of appeals on the government portal and prescribed staggered filing windows to avoid portal capacity and concurrency issues, allocating specific filing periods based on when first-instance appeals or revision notices were originally filed; the staggered schedule runs from 24.09.2025 to various deadlines not later than 30.06.2026. The measure invokes procedural rule powers to manage system load, applies to appeals under the CGST Act sections covering first appeals and revisions, and preserves the tribunal's substantive powers under the Act.
Note: It is a system-generated summary and is for quick reference only.
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