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...
On an application for condonation of delay in filing Form 10B under section 119(2)(b), the HC held that the authority had to confine itself to the explanation for delay and could not reject relief on an unrelated ground. The petitioner had explained that the audit report was uploaded within time and that the delay arose only in portal acceptance or verification. By refusing condonation because the registration certificate under section 12AA was not produced, the authority exceeded the limited scope of inquiry. The order was quashed and the matter remanded for fresh consideration of the delay explanation alone.
On an application for condonation of delay in filing Form 10B under section 119(2)(b), the HC held that the authority had to confine itself to the explanation for delay and could not reject relief on an unrelated ground. The petitioner had explained that the audit report was uploaded within time and that the delay arose only in portal acceptance or verification. By refusing condonation because the registration certificate under section 12AA was not produced, the authority exceeded the limited scope of inquiry. The order was quashed and the matter remanded for fresh consideration of the delay explanation alone.
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