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...
Challenge to the legality of Central and State notifications extending time under Section 73(10) CGST/RGST was addressed by permitting an interim procedural remedy: the petitioner may file a statutory appeal against assessment orders within four weeks. The Court exercised discretion to grant this limited time as an accommodation without prejudicing the pending substantive challenge to the Notifications before the Supreme Court. The appellate proceedings are expressly made subject to the ultimate determination on the Notifications' validity, and applications for condonation of delay and exemption of filings were allowed.
Challenge to the legality of Central and State notifications extending time under Section 73(10) CGST/RGST was addressed by permitting an interim procedural remedy: the petitioner may file a statutory appeal against assessment orders within four weeks. The Court exercised discretion to grant this limited time as an accommodation without prejudicing the pending substantive challenge to the Notifications before the Supreme Court. The appellate proceedings are expressly made subject to the ultimate determination on the Notifications' validity, and applications for condonation of delay and exemption of filings were allowed.
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