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 order cancelling petitioner's registration was passed without assigning any reasons, violating court precedents mandating reasons as the heart and soul of judicial and administrative orders. The appeal's dismissal on limitation grounds does not attract the doctrine of merger given the circumstances. Citing previous judgments, the court emphasized providing notice and opportunity for revocation before cancellation to prevent business disruption when no dues remain. Consequently, the Assistant Commissioner's order dated 21.08.2023 cancelling petitioner's registration was quashed, and the petition was allowed.
The order cancelling petitioner's registration was passed without assigning any reasons, violating court precedents mandating reasons as the heart and soul of judicial and administrative orders. The appeal's dismissal on limitation grounds does not attract the doctrine of merger given the circumstances. Citing previous judgments, the court emphasized providing notice and opportunity for revocation before cancellation to prevent business disruption when no dues remain. Consequently, the Assistant Commissioner's order dated 21.08.2023 cancelling petitioner's registration was quashed, and the petition was allowed.
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