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 the appeal had been rejected on limitation, though partial tax liability was admitted. Total tax demand was Rs. 9,99,558/-, of which the petitioner had accepted Rs. 3,65,918/- but deposited only Rs. 99,956/-. HC directed the petitioner to deposit the balance admitted tax of Rs. 2,65,962/- within 30 days, and additionally to deposit Rs. 1,58,410/-, being 25% of the disputed tax of Rs. 6,33,640/-, from the petitioner's Electronic Cash Register within the same period. On such compliance, the 1st respondent/Appellate Authority was mandated to entertain the appeal and decide it on merits, without rejecting it on the ground of limitation. The petition was disposed of with these directions.
HC held that the appeal had been rejected on limitation, though partial tax liability was admitted. Total tax demand was Rs. 9,99,558/-, of which the petitioner had accepted Rs. 3,65,918/- but deposited only Rs. 99,956/-. HC directed the petitioner to deposit the balance admitted tax of Rs. 2,65,962/- within 30 days, and additionally to deposit Rs. 1,58,410/-, being 25% of the disputed tax of Rs. 6,33,640/-, from the petitioner's Electronic Cash Register within the same period. On such compliance, the 1st respondent/Appellate Authority was mandated to entertain the appeal and decide it on merits, without rejecting it on the ground of limitation. The petition was disposed of with these directions.
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