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...
Cancellation of GST registration under Section 29 requires the Proper Officer's independent satisfaction, based on cogent and tangible material, that a statutory ground for cancellation exists. Nil turnover declared in GSTR-3B returns alone does not establish discontinuance of business, especially where material indicates that business continued from the registered premises. A show-cause notice founded solely on nil turnover does not disclose a circumstance warranting cancellation. The cancellation and rejection of revocation were quashed, while the authority retained liberty to verify whether the business continued and proceed in accordance with law.
Cancellation of GST registration under Section 29 requires the Proper Officer's independent satisfaction, based on cogent and tangible material, that a statutory ground for cancellation exists. Nil turnover declared in GSTR-3B returns alone does not establish discontinuance of business, especially where material indicates that business continued from the registered premises. A show-cause notice founded solely on nil turnover does not disclose a circumstance warranting cancellation. The cancellation and rejection of revocation were quashed, while the authority retained liberty to verify whether the business continued and proceed in accordance with law.
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