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 of the petitioner with retrospective effect - The High court observed that cancellation with retrospective effect should be based on objective criteria and not merely due to non-filing of returns. - The consequences of retrospective cancellation, such as denial of input tax credit to customers, were considered. - Both the petitioner and the department sought cancellation of GST registration, albeit for different reasons. - The impugned order was modified, and the registration was treated as cancelled from the date of the show cause notice, i.e., 11.07.2023.
Cancellation of GST registration of the petitioner with retrospective effect - The High court observed that cancellation with retrospective effect should be based on objective criteria and not merely due to non-filing of returns. - The consequences of retrospective cancellation, such as denial of input tax credit to customers, were considered. - Both the petitioner and the department sought cancellation of GST registration, albeit for different reasons. - The impugned order was modified, and the registration was treated as cancelled from the date of the show cause notice, i.e., 11.07.2023.
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