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 of petitioner - The High Court acknowledges that the show cause notice was served solely through the portal and not through other means such as email or letter. Considering the petitioner's lack of familiarity with the system and the failure of their previous accountant to inform them about the non-filing of returns, the Court finds merit in the petitioner's argument. The Court notes that the cancellation occurred without giving the petitioner an opportunity to be heard, which is against the principles of natural justice. - The Court considers the petitioner's personal circumstances and directs them to file an appeal within 30 days, ensuring the appeal is entertained without considering the issue of limitation.
Cancellation of GST registration of petitioner - The High Court acknowledges that the show cause notice was served solely through the portal and not through other means such as email or letter. Considering the petitioner's lack of familiarity with the system and the failure of their previous accountant to inform them about the non-filing of returns, the Court finds merit in the petitioner's argument. The Court notes that the cancellation occurred without giving the petitioner an opportunity to be heard, which is against the principles of natural justice. - The Court considers the petitioner's personal circumstances and directs them to file an appeal within 30 days, ensuring the appeal is entertained without considering the issue of limitation.
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