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...
Seeking to revoke the cancellation of GST registration - The petitioner, a university, contended that despite fulfilling tax obligations and filing returns until a certain period, their registration was cancelled, allegedly infringing upon constitutional rights and principles of natural justice. The court noted a delay in submitting returns but recognized the petitioner's efforts to rectify the situation by promptly clearing outstanding dues. While the petitioner had not submitted a specific application for revocation as required by law, they undertook to do so within a stipulated timeframe. Considering precedents emphasizing caution in cancelling GST registrations, the court adopted a pragmatic approach, ultimately allowing the petition and directing the restoration of GST registration.
Seeking to revoke the cancellation of GST registration - The petitioner, a university, contended that despite fulfilling tax obligations and filing returns until a certain period, their registration was cancelled, allegedly infringing upon constitutional rights and principles of natural justice. The court noted a delay in submitting returns but recognized the petitioner's efforts to rectify the situation by promptly clearing outstanding dues. While the petitioner had not submitted a specific application for revocation as required by law, they undertook to do so within a stipulated timeframe. Considering precedents emphasizing caution in cancelling GST registrations, the court adopted a pragmatic approach, ultimately allowing the petition and directing the restoration of GST registration.
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