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...
A show cause notice seeking cancellation of GST registration must disclose the alleged contraventions and follow the procedure prescribed in Rules 21 and 22. In the absence of a detailed notice setting out the shortcomings, the cancellation order and the appellate order were treated as unsustainable and were set aside. The authority was permitted to issue a fresh notice and proceed afresh in accordance with law, while the taxpayer was directed not to avail input tax credit until the proceedings are finalised.
A show cause notice seeking cancellation of GST registration must disclose the alleged contraventions and follow the procedure prescribed in Rules 21 and 22. In the absence of a detailed notice setting out the shortcomings, the cancellation order and the appellate order were treated as unsustainable and were set aside. The authority was permitted to issue a fresh notice and proceed afresh in accordance with law, while the taxpayer was directed not to avail input tax credit until the proceedings are finalised.
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