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...
Violation of principles of natural justice - Show cause notice did not disclose reasons for cancellation of petitioner's GST registration. Mere disclosure of reasons does not satisfy Rule 25 of GST Rules regarding physical verification of business premises. Respondents did not notify petitioners about attempt to identify petitioner's place of business. Postal endorsement alone cannot establish non-existence of company. Procedure adopted by respondents may not strictly follow rules but cannot be deemed illegal, especially when petitioners are unwilling for further inspection, raising presumption of withholding information. Petitioners not entitled to relief under Article 226, petition dismissed.
Violation of principles of natural justice - Show cause notice did not disclose reasons for cancellation of petitioner's GST registration. Mere disclosure of reasons does not satisfy Rule 25 of GST Rules regarding physical verification of business premises. Respondents did not notify petitioners about attempt to identify petitioner's place of business. Postal endorsement alone cannot establish non-existence of company. Procedure adopted by respondents may not strictly follow rules but cannot be deemed illegal, especially when petitioners are unwilling for further inspection, raising presumption of withholding information. Petitioners not entitled to relief under Article 226, petition dismissed.
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