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...
Retrospective cancellation of GST registration without assigning reasons violates principles of natural justice. The impugned order lacked reasoning for cancelling registration retrospectively from a particular date, having cascading effect on input tax credit. Mere allegation of non-existence was insufficient, as petitioner substantiated temporary suspension due to ill health. Abject failure to conduct enquiry or provide reasons for retrospective cancellation renders the order unsustainable. Authorities directed to restore petitioner's GST registration after setting aside the impugned show cause notices and cancellation orders.
Retrospective cancellation of GST registration without assigning reasons violates principles of natural justice. The impugned order lacked reasoning for cancelling registration retrospectively from a particular date, having cascading effect on input tax credit. Mere allegation of non-existence was insufficient, as petitioner substantiated temporary suspension due to ill health. Abject failure to conduct enquiry or provide reasons for retrospective cancellation renders the order unsustainable. Authorities directed to restore petitioner's GST registration after setting aside the impugned show cause notices and cancellation orders.
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