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...
SCN does not clearly reflect reasons for proposed cancellation of petitioner's GST registration, violating principles of natural justice. Show cause notice must specify allegations with necessary details to elicit meaningful response. Without details, noticee remains clueless about case to be met. Impugned order lacks reasoning for cancellation except referring to impugned SCN, violating natural justice. Impugned SCN and order set aside, petitioner's GST registration directed to be restored forthwith, petition disposed of.
SCN does not clearly reflect reasons for proposed cancellation of petitioner's GST registration, violating principles of natural justice. Show cause notice must specify allegations with necessary details to elicit meaningful response. Without details, noticee remains clueless about case to be met. Impugned order lacks reasoning for cancellation except referring to impugned SCN, violating natural justice. Impugned SCN and order set aside, petitioner's GST registration directed to be restored forthwith, petition disposed of.
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