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...
Under the parallel CGST and State GST framework, State-wise registration does not permit a taxpayer to evade compliance by shifting business to another State. Where a company has obtained registration in one State but failed to file returns, leading to cancellation or suspension of that registration, it remains a defaulter under the GST scheme. That default can justify refusal of registration in another State until the earlier statutory obligations are complied with. The HC upheld denial of GST registration in Rajasthan based on non-compliance in Tamil Nadu and dismissed the writ petition.
Under the parallel CGST and State GST framework, State-wise registration does not permit a taxpayer to evade compliance by shifting business to another State. Where a company has obtained registration in one State but failed to file returns, leading to cancellation or suspension of that registration, it remains a defaulter under the GST scheme. That default can justify refusal of registration in another State until the earlier statutory obligations are complied with. The HC upheld denial of GST registration in Rajasthan based on non-compliance in Tamil Nadu and dismissed the writ petition.
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