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...
Amendment of CST Registration Certificate - the application for amending the CST Registration Certificate has been made belatedly on 19.09.2020, nevertheless, there is no embargo under the aforesaid Rules to amend the date in the CST Registration Certificate - the records will be available with the respondents and therefore the respondents cannot reject the request of the petitioner merely stating that it is not possible to amend the Certificate at a later point of time. It was for the respondents to make suitable internal changes in their Web Portal to amend the Certificates of registration. - HC
Amendment of CST Registration Certificate - the application for amending the CST Registration Certificate has been made belatedly on 19.09.2020, nevertheless, there is no embargo under the aforesaid Rules to amend the date in the CST Registration Certificate - the records will be available with the respondents and therefore the respondents cannot reject the request of the petitioner merely stating that it is not possible to amend the Certificate at a later point of time. It was for the respondents to make suitable internal changes in their Web Portal to amend the Certificates of registration. - HC
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