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...
Condonation of delay in filing appeal before appellate authority - Revocation of cancellation of 'GST' registration - non filing of GST returns - In the case on hand, computed from 01.03.2022, 90 days period elapsed on 30.05.2022 and further condonable period of one month elapsed on 30.06.2022. - no ground to interfere with the impugned order. - Before writing the sequitur and dropping the curtains on the captioned writ petition, it is deemed appropriate to record that this Writ Court is informed that it is open to writ petitioner to apply for GST registration afresh. - HC
Condonation of delay in filing appeal before appellate authority - Revocation of cancellation of 'GST' registration - non filing of GST returns - In the case on hand, computed from 01.03.2022, 90 days period elapsed on 30.05.2022 and further condonable period of one month elapsed on 30.06.2022. - no ground to interfere with the impugned order. - Before writing the sequitur and dropping the curtains on the captioned writ petition, it is deemed appropriate to record that this Writ Court is informed that it is open to writ petitioner to apply for GST registration afresh. - HC
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