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 retrospectively - Show Cause Notice issued without giving reasons of cancellation - The High court observed that the Show Cause Notice lacked clarity regarding the reason for cancellation and did not provide the petitioner with an opportunity to object to the retrospective cancellation. - The impugned order did not give reasons for cancellation and contained contradictory statements regarding the submission of replies. - Considering that the petitioner no longer seeks to continue business, the court modified the impugned order to cancel the registration from the date of the Show Cause Notice.
Cancellation Of GST registration retrospectively - Show Cause Notice issued without giving reasons of cancellation - The High court observed that the Show Cause Notice lacked clarity regarding the reason for cancellation and did not provide the petitioner with an opportunity to object to the retrospective cancellation. - The impugned order did not give reasons for cancellation and contained contradictory statements regarding the submission of replies. - Considering that the petitioner no longer seeks to continue business, the court modified the impugned order to cancel the registration from the date of the Show Cause Notice.
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