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...
Cancellation of a petitioner's Goods and Services Tax (GST) registration. The Show Cause Notice (SCN) did not provide specific details of the allegations, violating principles of natural justice. The petitioner had applied for revocation of the cancellation order, stating that business activities were halted due to COVID-19 but would resume gradually. The petitioner provided property tax receipts and explained ownership of the principal place of business. The cancellation order was passed by the Proper Officer based on directions from another authority, which was impermissible. The Proper Officer was required to independently assess the reasons for cancellation. The High Court set aside the SCN, cancellation order, and appellate order, directing the respondents to restore the petitioner's GST registration forthwith.
Cancellation of a petitioner's Goods and Services Tax (GST) registration. The Show Cause Notice (SCN) did not provide specific details of the allegations, violating principles of natural justice. The petitioner had applied for revocation of the cancellation order, stating that business activities were halted due to COVID-19 but would resume gradually. The petitioner provided property tax receipts and explained ownership of the principal place of business. The cancellation order was passed by the Proper Officer based on directions from another authority, which was impermissible. The Proper Officer was required to independently assess the reasons for cancellation. The High Court set aside the SCN, cancellation order, and appellate order, directing the respondents to restore the petitioner's GST registration forthwith.
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