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...
Maintainability of appeal - time limitation - Cancellation of GST registration of petitioner - failure to submit GST returns for a continuous period of six months - Despite the dismissal of the appeal on limitation grounds, the Court asserted its jurisdiction to review the original authority's decision. Recognizing the petitioner's genuine reasons and societal contributions, the Court set aside the cancellation order, directing the authority to reconsider the revocation request with reasonable opportunity for the petitioner.
Maintainability of appeal - time limitation - Cancellation of GST registration of petitioner - failure to submit GST returns for a continuous period of six months - Despite the dismissal of the appeal on limitation grounds, the Court asserted its jurisdiction to review the original authority's decision. Recognizing the petitioner's genuine reasons and societal contributions, the Court set aside the cancellation order, directing the authority to reconsider the revocation request with reasonable opportunity for the petitioner.
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