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 requires specific reasons in the show cause notice and final order; without such reasons, cancellation cannot be given effect from the original registration date. The HC set aside the order only to that extent and remitted the matter to the Proper Officer for fresh consideration after allowing the taxpayer to file a detailed reply and after hearing. It did not examine the merits of the allegation that no business existed at the declared premises, and confined relief to the effective date of cancellation.
Retrospective cancellation of GST registration requires specific reasons in the show cause notice and final order; without such reasons, cancellation cannot be given effect from the original registration date. The HC set aside the order only to that extent and remitted the matter to the Proper Officer for fresh consideration after allowing the taxpayer to file a detailed reply and after hearing. It did not examine the merits of the allegation that no business existed at the declared premises, and confined relief to the effective date of cancellation.
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