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...
Ex parte cancellation of GST registration can be set aside conditionally where the taxpayer is willing to regularise the default by filing pending returns and paying the consequential tax, interest and penalty. The HC stated that restoration should be granted on compliance within a reasonable time, and directed that the registration be restored after the portal is enabled if the petitioner uploads all pending returns and makes the required payments within the time granted. The cancellation order and the appellate order were quashed subject to that compliance, with liberty to the authorities to proceed according to law on default.
Ex parte cancellation of GST registration can be set aside conditionally where the taxpayer is willing to regularise the default by filing pending returns and paying the consequential tax, interest and penalty. The HC stated that restoration should be granted on compliance within a reasonable time, and directed that the registration be restored after the portal is enabled if the petitioner uploads all pending returns and makes the required payments within the time granted. The cancellation order and the appellate order were quashed subject to that compliance, with liberty to the authorities to proceed according to law on default.
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