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 - The High court observed that the Show Cause Notice and the impugned order lacked necessary details and reasoning for retrospective cancellation, rendering them unsustainable. - Section 29(2) of the Central Goods and Services Tax Act, 2017 was referenced, emphasizing that cancellation with retrospective effect should be based on objective criteria and not merely due to non-filing of returns. - Consequently, the impugned order dated 29.02.2024 was set aside, and the petitioner's GST registration was restored, with a directive to comply with necessary regulations.
Cancellation Of GST registration retrospectively - The High court observed that the Show Cause Notice and the impugned order lacked necessary details and reasoning for retrospective cancellation, rendering them unsustainable. - Section 29(2) of the Central Goods and Services Tax Act, 2017 was referenced, emphasizing that cancellation with retrospective effect should be based on objective criteria and not merely due to non-filing of returns. - Consequently, the impugned order dated 29.02.2024 was set aside, and the petitioner's GST registration was restored, with a directive to comply with necessary regulations.
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