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...
The Central Goods and Services Tax (CGST) Authority accepted the petitioner's voluntary application for cancellation of registration with effect from 8th May 2023. However, the subsequent orders revoking the registration cancellation were passed contrary to the principles of natural justice. Consequently, all proceedings initiated thereafter were quashed. The petitioner's conduct of overlooking the show cause notice was not approved. To balance interests, the petitioner will be restrained from utilizing the Input Tax Credit (ITC) for a reasonable period during which the respondents must conclude proceedings. The orders dated 20th February 2024, 8th March 2024, and 9th May 2024 were quashed, restoring the position as of 8th May 2023, the date of acceptance of the petitioner's application for registration cancellation. The petition was disposed of accordingly.
The Central Goods and Services Tax (CGST) Authority accepted the petitioner's voluntary application for cancellation of registration with effect from 8th May 2023. However, the subsequent orders revoking the registration cancellation were passed contrary to the principles of natural justice. Consequently, all proceedings initiated thereafter were quashed. The petitioner's conduct of overlooking the show cause notice was not approved. To balance interests, the petitioner will be restrained from utilizing the Input Tax Credit (ITC) for a reasonable period during which the respondents must conclude proceedings. The orders dated 20th February 2024, 8th March 2024, and 9th May 2024 were quashed, restoring the position as of 8th May 2023, the date of acceptance of the petitioner's application for registration cancellation. The petition was disposed of accordingly.
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