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 set aside GST registration cancellation and appellate authority's order, granting petitioner one final opportunity to remedy default. Following precedent in Subhankar Golder case, court allowed restoration of GST registration conditional upon petitioner filing all pending returns and paying applicable tax, interest, penalties within four weeks. Failure to comply would result in automatic dismissal of petition and immediate reinstatement of registration cancellation. Decision balanced regulatory compliance with business continuity, particularly considering small retailer status. Court emphasized need for tax compliance while providing reasonable opportunity for rectification.
HC set aside GST registration cancellation and appellate authority's order, granting petitioner one final opportunity to remedy default. Following precedent in Subhankar Golder case, court allowed restoration of GST registration conditional upon petitioner filing all pending returns and paying applicable tax, interest, penalties within four weeks. Failure to comply would result in automatic dismissal of petition and immediate reinstatement of registration cancellation. Decision balanced regulatory compliance with business continuity, particularly considering small retailer status. Court emphasized need for tax compliance while providing reasonable opportunity for rectification.
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