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...
GST registration cancelled for non-filing of returns may be restored where the registered person furnishes all pending returns and pays the tax dues with applicable interest, penalty and late fee, because the proper officer can consider dropping proceedings under the proviso to Rule 22(4). The text notes that the High Court treated the matter as covered by an earlier coordinate Bench decision and allowed the assessee to approach the authority for restoration in accordance with law. It also records a direction that the limitation period for assessment proceedings would run from the date of the order, except for FY 2024-25, which would be governed separately.
GST registration cancelled for non-filing of returns may be restored where the registered person furnishes all pending returns and pays the tax dues with applicable interest, penalty and late fee, because the proper officer can consider dropping proceedings under the proviso to Rule 22(4). The text notes that the High Court treated the matter as covered by an earlier coordinate Bench decision and allowed the assessee to approach the authority for restoration in accordance with law. It also records a direction that the limitation period for assessment proceedings would run from the date of the order, except for FY 2024-25, which would be governed separately.
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