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...
Cancelled GST registration for non-filing of returns over six months was considered fit for restoration where no allegation of fraud or unlawful activity was shown, the default was linked to financial hardship and Covid-19 disruption, and the taxpayer expressed readiness to clear statutory dues. Restoration was made conditional on the authorities first ascertaining and intimating the outstanding tax, interest and late fee or penalty, and on payment within the stipulated time; failing payment, the petition would stand dismissed.
Cancelled GST registration for non-filing of returns over six months was considered fit for restoration where no allegation of fraud or unlawful activity was shown, the default was linked to financial hardship and Covid-19 disruption, and the taxpayer expressed readiness to clear statutory dues. Restoration was made conditional on the authorities first ascertaining and intimating the outstanding tax, interest and late fee or penalty, and on payment within the stipulated time; failing payment, the petition would stand dismissed.
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