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...
Condonation of delay in receipt of export remittance under the CGST framework requires a reasoned order and opportunity for hearing; a mere communication or intimation cannot substitute for an order. The impugned communication purportedly rejecting the petitioner's representation was not a reasoned order and no hearing was afforded. The matter is remitted to the competent commissioner to reconsider the condonation request afresh, afford the petitioner an opportunity to be heard, and pass a reasoned decision addressing the grounds raised by the petitioner.
Condonation of delay in receipt of export remittance under the CGST framework requires a reasoned order and opportunity for hearing; a mere communication or intimation cannot substitute for an order. The impugned communication purportedly rejecting the petitioner's representation was not a reasoned order and no hearing was afforded. The matter is remitted to the competent commissioner to reconsider the condonation request afresh, afford the petitioner an opportunity to be heard, and pass a reasoned decision addressing the grounds raised by the petitioner.
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