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 invalidated the retrospective cancellation of GST registration due to procedural deficiencies in the show cause notice (SCN). The original SCN failed to disclose the intent for retrospective cancellation or provide supporting reasons, violating principles of natural justice. The Court determined that absence of prior notice regarding retrospective action rendered the cancellation order invalid from February 13, 2024. While upholding the cancellation itself, the Court modified the effective date to align with the SCN issuance date of November 7, 2024, ensuring procedural fairness and due process in administrative action.
HC invalidated the retrospective cancellation of GST registration due to procedural deficiencies in the show cause notice (SCN). The original SCN failed to disclose the intent for retrospective cancellation or provide supporting reasons, violating principles of natural justice. The Court determined that absence of prior notice regarding retrospective action rendered the cancellation order invalid from February 13, 2024. While upholding the cancellation itself, the Court modified the effective date to align with the SCN issuance date of November 7, 2024, ensuring procedural fairness and due process in administrative action.
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