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 disposed of writ petition challenging GST registration cancellation under Section 29(2)(c) for non-filing of returns exceeding six months. Court held that despite elapsed time limit for revocation application, petitioner may approach empowered officer within two months to seek restoration by furnishing all pending returns and making full payment of tax dues with applicable interest and late fees. Court relied on proviso to sub-rule (4) of Rule 22 CGST Rules 2017, which permits dropping proceedings upon compliance. Given serious civil consequences of cancellation, HC directed concerned authority to consider restoration upon petitioner's compliance with statutory requirements including complete return filing and payment obligations.
HC disposed of writ petition challenging GST registration cancellation under Section 29(2)(c) for non-filing of returns exceeding six months. Court held that despite elapsed time limit for revocation application, petitioner may approach empowered officer within two months to seek restoration by furnishing all pending returns and making full payment of tax dues with applicable interest and late fees. Court relied on proviso to sub-rule (4) of Rule 22 CGST Rules 2017, which permits dropping proceedings upon compliance. Given serious civil consequences of cancellation, HC directed concerned authority to consider restoration upon petitioner's compliance with statutory requirements including complete return filing and payment obligations.
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