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...
The High Court addressed the cancellation of the petitioner's GST registration due to non-filing of returns for 6 months. The court noted no tax evasion but dismissal of appeal on limitation grounds. Recognizing the adverse impact on revenue, the court set aside the registration cancellation order from May 27, 2020. The petitioner must file all pending returns, pay taxes, interest, fines, and penalties. The court disposed of the petition, emphasizing a pragmatic approach by authorities to allow the petitioner to continue business operations.
The High Court addressed the cancellation of the petitioner's GST registration due to non-filing of returns for 6 months. The court noted no tax evasion but dismissal of appeal on limitation grounds. Recognizing the adverse impact on revenue, the court set aside the registration cancellation order from May 27, 2020. The petitioner must file all pending returns, pay taxes, interest, fines, and penalties. The court disposed of the petition, emphasizing a pragmatic approach by authorities to allow the petitioner to continue business operations.
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