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...
CESTAT addressed condonation of delay and proof-of-delivery requirements in a service tax appeal: the Tribunal directed deposit of a cost to condone inordinate delay in filing the appeal and linked grant of appeal number to compliance; it recognised that statutory ''acknowledgement due'' evidence (AD card or Speed Post tracking showing actual receipt) is mandatory for proving service, and in its absence the department must maintain and produce such proof to prevent frivolous admissions; the Tribunal noted recovery steps including bank account freezing and directed communication of this order to CBIC for systemic remedy.
CESTAT addressed condonation of delay and proof-of-delivery requirements in a service tax appeal: the Tribunal directed deposit of a cost to condone inordinate delay in filing the appeal and linked grant of appeal number to compliance; it recognised that statutory ''acknowledgement due'' evidence (AD card or Speed Post tracking showing actual receipt) is mandatory for proving service, and in its absence the department must maintain and produce such proof to prevent frivolous admissions; the Tribunal noted recovery steps including bank account freezing and directed communication of this order to CBIC for systemic remedy.
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