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 dismissed the writ petition filed by the petitioner company, holding that appeals under Section 107 of the Act are subject to the statutory limitation (four months under ss.107(1) and (4)) and that the delay in filing could not be condoned. The court relied on prior co-ordinate bench precedent affirming strict adherence to the limitation period. Findings of no breach of natural justice were recorded, as the petitioner had participated in the proceedings and received the Order-in-Original. The petitioner's reliance on the alleged illegibility of the order was rejected as a procedural remedy available to the petitioner which was not availed. Petition accordingly dismissed and matters disposed.
The HC dismissed the writ petition filed by the petitioner company, holding that appeals under Section 107 of the Act are subject to the statutory limitation (four months under ss.107(1) and (4)) and that the delay in filing could not be condoned. The court relied on prior co-ordinate bench precedent affirming strict adherence to the limitation period. Findings of no breach of natural justice were recorded, as the petitioner had participated in the proceedings and received the Order-in-Original. The petitioner's reliance on the alleged illegibility of the order was rejected as a procedural remedy available to the petitioner which was not availed. Petition accordingly dismissed and matters disposed.
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