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...
Validity of show cause notice issued threatening cancellation of GSTIN registration for non filing of returns - The case revolves around the timely filing of an appeal against the cancellation of GSTIN registration. The petitioner, a registered person under GST laws, challenged the cancellation order issued on 06.04.2023, which was rejected on the grounds of being filed belatedly. However, the petitioner contended that returns were promptly filed upon receiving the show cause notice, and the subsequent cancellation order was based on procedural grounds despite having no outstanding tax dues. The court, finding merit in the petitioner's submissions, quashed the impugned order and directed the appellate authority to reconsider the matter on its merits within a specified time frame.
Validity of show cause notice issued threatening cancellation of GSTIN registration for non filing of returns - The case revolves around the timely filing of an appeal against the cancellation of GSTIN registration. The petitioner, a registered person under GST laws, challenged the cancellation order issued on 06.04.2023, which was rejected on the grounds of being filed belatedly. However, the petitioner contended that returns were promptly filed upon receiving the show cause notice, and the subsequent cancellation order was based on procedural grounds despite having no outstanding tax dues. The court, finding merit in the petitioner's submissions, quashed the impugned order and directed the appellate authority to reconsider the matter on its merits within a specified time frame.
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