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...
The HC quashed the GST registration cancellation order, finding it procedurally deficient as a non-speaking order that failed to conform with FORM GST REG-19 requirements. Despite the petitioner's delayed approach (filing after approximately one year), the Court determined that the order's statutory non-compliance outweighed concerns about delay. The Court remanded the matter to the show cause notice stage, providing the petitioner two options: either submit a reply demonstrating why registration should not be cancelled under Rule 22(2) of CGST Rules read with Section 29(2)(c) of CGST Act, or furnish all pending returns with full payment of tax dues, applicable interest, late fees and penalties.
The HC quashed the GST registration cancellation order, finding it procedurally deficient as a non-speaking order that failed to conform with FORM GST REG-19 requirements. Despite the petitioner's delayed approach (filing after approximately one year), the Court determined that the order's statutory non-compliance outweighed concerns about delay. The Court remanded the matter to the show cause notice stage, providing the petitioner two options: either submit a reply demonstrating why registration should not be cancelled under Rule 22(2) of CGST Rules read with Section 29(2)(c) of CGST Act, or furnish all pending returns with full payment of tax dues, applicable interest, late fees and penalties.
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