Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Belated statutory appeals under GST may still be entertained conditionally where the court exercises discretion despite expiry of limitation. The text explains that the writ challenge was not accepted on merits because the petitioner had not used the statutory reduced-penalty amnesty and had approached the court after the appeal period had lapsed. Even so, the court granted liberty to file an appeal within the time fixed, subject to pre-deposit of 25% of the disputed tax. On compliance, the appellate authority was directed to hear the appeal on merits, adjust any amount already recovered toward the pre-deposit, and lift bank attachment if applicable.
Belated statutory appeals under GST may still be entertained conditionally where the court exercises discretion despite expiry of limitation. The text explains that the writ challenge was not accepted on merits because the petitioner had not used the statutory reduced-penalty amnesty and had approached the court after the appeal period had lapsed. Even so, the court granted liberty to file an appeal within the time fixed, subject to pre-deposit of 25% of the disputed tax. On compliance, the appellate authority was directed to hear the appeal on merits, adjust any amount already recovered toward the pre-deposit, and lift bank attachment if applicable.
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