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 GST registration without providing opportunity to be heard violated principles of natural justice. Appeal filed by petitioner rejected due to expiry of limitation period u/s 107 of CGST Act, 2017. Show cause notice issued to petitioner for failure to furnish returns for six consecutive months. Petitioner claimed no reply filed within stipulated period, denying principles of natural justice. However, petitioner failed to furnish returns for six months and filed appeal after delay of one year and twenty days, beyond three-month limitation period u/s 107(1). Petitioner's lethargic approach in not filing returns and delayed appeal filing led to dismissal of writ petition, as no perversity found in cancellation order or appellate order beyond statutory limitation period.
Cancellation of GST registration without providing opportunity to be heard violated principles of natural justice. Appeal filed by petitioner rejected due to expiry of limitation period u/s 107 of CGST Act, 2017. Show cause notice issued to petitioner for failure to furnish returns for six consecutive months. Petitioner claimed no reply filed within stipulated period, denying principles of natural justice. However, petitioner failed to furnish returns for six months and filed appeal after delay of one year and twenty days, beyond three-month limitation period u/s 107(1). Petitioner's lethargic approach in not filing returns and delayed appeal filing led to dismissal of writ petition, as no perversity found in cancellation order or appellate order beyond statutory limitation period.
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