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-furnishing returns for six months. Court found violation of natural justice principles as no personal hearing date was notified to petitioner. HC directed petitioner to approach concerned authority within two months seeking restoration by filing pending returns and paying tax dues with interest and late fees. Court held that if petitioner complies with proviso to Rule 22(4) of CGST Rules 2017, authority must consider restoration application expeditiously in accordance with law, given serious civil consequences of registration cancellation.
HC disposed of writ petition challenging GST registration cancellation under Section 29(2)(c) for non-furnishing returns for six months. Court found violation of natural justice principles as no personal hearing date was notified to petitioner. HC directed petitioner to approach concerned authority within two months seeking restoration by filing pending returns and paying tax dues with interest and late fees. Court held that if petitioner complies with proviso to Rule 22(4) of CGST Rules 2017, authority must consider restoration application expeditiously in accordance with law, given serious civil consequences of registration cancellation.
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