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...
HC ruled that GST registration cancellation proceedings can be dropped if the registered person files pending returns and makes full tax payment with interest and late fees as per Rule 22(4) of CGST Rules 2017. The petitioner was granted two months to approach the authority for registration restoration. Upon submission of application and compliance with Rule 22(4) requirements, the authority must expeditiously consider restoration of petitioner's GST registration in accordance with law. The ruling emphasizes administrative discretion to restore registration when statutory compliance is achieved.
HC ruled that GST registration cancellation proceedings can be dropped if the registered person files pending returns and makes full tax payment with interest and late fees as per Rule 22(4) of CGST Rules 2017. The petitioner was granted two months to approach the authority for registration restoration. Upon submission of application and compliance with Rule 22(4) requirements, the authority must expeditiously consider restoration of petitioner's GST registration in accordance with law. The ruling emphasizes administrative discretion to restore registration when statutory compliance is achieved.
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