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...
Mandatory filing requirement of Form GST DRC-07 was central to a challenge to delay in preferring an appeal under the statutory limitation for appeals; the article emphasises that where delay is sought to be condoned on the basis of failure to upload a mandatory form, the appellate authority must expressly consider the grounds set out in the memo of appeal when adjudicating a condonation application. Failure to advert to those grounds vitiates the appellate decision and may require setting aside the order impugned.
Mandatory filing requirement of Form GST DRC-07 was central to a challenge to delay in preferring an appeal under the statutory limitation for appeals; the article emphasises that where delay is sought to be condoned on the basis of failure to upload a mandatory form, the appellate authority must expressly consider the grounds set out in the memo of appeal when adjudicating a condonation application. Failure to advert to those grounds vitiates the appellate decision and may require setting aside the order impugned.
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