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...
An appellate order directing restoration of GST registration must be implemented unless it is stayed, because mere filing of a further departmental appeal does not create an automatic stay in the absence of statutory provision. The Court found the revenue's refusal to comply with the unstayed direction arbitrary and unreasonable, especially where the appellate authority had already set aside the cancellation refusal and positively ordered restoration. The registration was therefore directed to be revived forthwith, subject to the outcome of the pending departmental appeal.
An appellate order directing restoration of GST registration must be implemented unless it is stayed, because mere filing of a further departmental appeal does not create an automatic stay in the absence of statutory provision. The Court found the revenue's refusal to comply with the unstayed direction arbitrary and unreasonable, especially where the appellate authority had already set aside the cancellation refusal and positively ordered restoration. The registration was therefore directed to be revived forthwith, subject to the outcome of the pending departmental appeal.
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