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...
Uploading the summary of a final order in FORM GST DRC-07 is a mandatory procedural requirement that functions as the notice of demand and preserves the taxpayer's statutory right to appeal; accordingly the court directed issuance/upload of DRC-07 to enable filing of an appeal despite the petitioner's delay. The decision relied on the statutory scheme and prior higher-court reasoning to treat the DRC-07 upload as essential for exercising appellate remedies. The court also recorded that, as a matter of substantive effect, a taxpayer is precluded from challenging a penalty once the penalty amount has been proved or paid under the relevant GST provisions.
Uploading the summary of a final order in FORM GST DRC-07 is a mandatory procedural requirement that functions as the notice of demand and preserves the taxpayer's statutory right to appeal; accordingly the court directed issuance/upload of DRC-07 to enable filing of an appeal despite the petitioner's delay. The decision relied on the statutory scheme and prior higher-court reasoning to treat the DRC-07 upload as essential for exercising appellate remedies. The court also recorded that, as a matter of substantive effect, a taxpayer is precluded from challenging a penalty once the penalty amount has been proved or paid under the relevant GST provisions.
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