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...
Retrospective cancellation of GST registration was treated as permissible because section 29(2) expressly allows cancellation from any date, and the second proviso was read within the same scheme to permit suspension during pending cancellation proceedings. The challenge to retrospective suspension was therefore rejected, and no basis was found to question section 29(2) or rule 21(a). The notice was also considered procedurally fair because it allowed a reply and personal hearing, so the writ challenge to the show-cause notice was declined and the objections were left to be raised before the authority.
Retrospective cancellation of GST registration was treated as permissible because section 29(2) expressly allows cancellation from any date, and the second proviso was read within the same scheme to permit suspension during pending cancellation proceedings. The challenge to retrospective suspension was therefore rejected, and no basis was found to question section 29(2) or rule 21(a). The notice was also considered procedurally fair because it allowed a reply and personal hearing, so the writ challenge to the show-cause notice was declined and the objections were left to be raised before the authority.
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