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...
Section 29(3) of CGST Act mandates that cancellation of GST registration does not affect liability to pay tax and other dues. Section 65(1) authorizes audit of any registered person. Petitioner was registered during audit period and show cause notice u/s 73 was issued after audit. Proceedings valid as "registered person" u/s 65 includes those registered during audit period. Petitioner who fraudulently availed ITC and later sought cancellation not entitled to relief. Petition dismissed with cost of Rs. 25,000/-.
Section 29(3) of CGST Act mandates that cancellation of GST registration does not affect liability to pay tax and other dues. Section 65(1) authorizes audit of any registered person. Petitioner was registered during audit period and show cause notice u/s 73 was issued after audit. Proceedings valid as "registered person" u/s 65 includes those registered during audit period. Petitioner who fraudulently availed ITC and later sought cancellation not entitled to relief. Petition dismissed with cost of Rs. 25,000/-.
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