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 declined to quash a show cause notice (SCN) issued for GST registration cancellation against a firm found non-functional during investigation. The Court determined that petitioner could seek re-inspection from the Adjudicating Authority rather than judicial intervention at this preliminary stage. However, recognizing the firm's operational standstill due to registration suspension, the HC directed the respondent department to grant petitioner a personal hearing and issue appropriate notice. The Court emphasized proceedings must conclude in a time-bound manner given the business disruption caused by the suspended registration. The petition was disposed of with these procedural directions rather than substantive relief on the merits of the cancellation proceedings.
The HC declined to quash a show cause notice (SCN) issued for GST registration cancellation against a firm found non-functional during investigation. The Court determined that petitioner could seek re-inspection from the Adjudicating Authority rather than judicial intervention at this preliminary stage. However, recognizing the firm's operational standstill due to registration suspension, the HC directed the respondent department to grant petitioner a personal hearing and issue appropriate notice. The Court emphasized proceedings must conclude in a time-bound manner given the business disruption caused by the suspended registration. The petition was disposed of with these procedural directions rather than substantive relief on the merits of the cancellation proceedings.
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