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 can be restored where the taxpayer files all pending returns and pays the tax dues, applicable interest and late fee, because the proviso to Rule 22(4) of the CGST Rules permits the proper officer to drop cancellation proceedings in such cases. As cancellation carries serious civil consequences, the authority must consider a proper restoration application in accordance with law once the statutory requirements are met. The text links this relief to principles of natural justice and the officer's power to restore registration on compliance.
GST registration cancelled for non-filing of returns can be restored where the taxpayer files all pending returns and pays the tax dues, applicable interest and late fee, because the proviso to Rule 22(4) of the CGST Rules permits the proper officer to drop cancellation proceedings in such cases. As cancellation carries serious civil consequences, the authority must consider a proper restoration application in accordance with law once the statutory requirements are met. The text links this relief to principles of natural justice and the officer's power to restore registration on compliance.
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