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 under the proviso to Section 100(2) of the CGST Act is discussed with focus on technical portal failure as sufficient cause; the note explains that repeated unsuccessful online filing attempts, corroborated by screenshots and a helpdesk ticket, can satisfy the requirement of prevention from presenting an appeal within the primary period and justify admission within the further thirty days. It states that, where such evidence is accepted, the appellate authority may invoke its power to condone delay and admit the appeal for adjudication on merits.
Condonation of delay under the proviso to Section 100(2) of the CGST Act is discussed with focus on technical portal failure as sufficient cause; the note explains that repeated unsuccessful online filing attempts, corroborated by screenshots and a helpdesk ticket, can satisfy the requirement of prevention from presenting an appeal within the primary period and justify admission within the further thirty days. It states that, where such evidence is accepted, the appellate authority may invoke its power to condone delay and admit the appeal for adjudication on merits.
Note: It is a system-generated summary and is for quick reference only.