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...
Retrospective cancellation of GST registration due to failure to file returns timely - impugned order does not set out any reason except referring to impugned show cause notice (SCN) - violation of principles of natural justice - Although Proper Officer has power to cancel GST registration from deemed fit date u/s 29(2) of CGST Act, such powers cannot be used arbitrarily - Decision to cancel registration with retrospective effect must be informed by reason - No reasons found in impugned SCN or order supporting cancellation of registration from date it was granted - Cancellation of GST registration to be effective from date of impugned SCN and not retrospectively - Petition disposed off.
Retrospective cancellation of GST registration due to failure to file returns timely - impugned order does not set out any reason except referring to impugned show cause notice (SCN) - violation of principles of natural justice - Although Proper Officer has power to cancel GST registration from deemed fit date u/s 29(2) of CGST Act, such powers cannot be used arbitrarily - Decision to cancel registration with retrospective effect must be informed by reason - No reasons found in impugned SCN or order supporting cancellation of registration from date it was granted - Cancellation of GST registration to be effective from date of impugned SCN and not retrospectively - Petition disposed off.
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