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...
Rejection of the petitioner's application for revocation of the cancellation order of GST registration. The key points are: the show cause notice (SCN) did not propose retrospective cancellation, violating natural justice principles. Section 29(2) of the CGST/DGST Act empowers retrospective cancellation, but it must be based on cogent reasons, not whimsically or arbitrarily. The impugned cancellation order lacked reasoning for retrospective cancellation. The High Court directed restoring the petitioner's GST registration for 30 days to file returns, after which the proper officer may consider further action if necessary. The summary covers the legal issues, statutory provisions, and the court's directions concisely.
Rejection of the petitioner's application for revocation of the cancellation order of GST registration. The key points are: the show cause notice (SCN) did not propose retrospective cancellation, violating natural justice principles. Section 29(2) of the CGST/DGST Act empowers retrospective cancellation, but it must be based on cogent reasons, not whimsically or arbitrarily. The impugned cancellation order lacked reasoning for retrospective cancellation. The High Court directed restoring the petitioner's GST registration for 30 days to file returns, after which the proper officer may consider further action if necessary. The summary covers the legal issues, statutory provisions, and the court's directions concisely.
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