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 impugned order insofar as it imposed retrospective cancellation of the petitioner's GST registration from 3 July 2017, holding that the cancellation with retrospective effect was unsustainable due to non-application of mind and lack of opportunity to represent against such retrospective action. The court directed that the cancellation shall take effect only from the date of issuance of the SCN, 27 June 2023. The petition was disposed of accordingly.
The HC quashed the impugned order insofar as it imposed retrospective cancellation of the petitioner's GST registration from 3 July 2017, holding that the cancellation with retrospective effect was unsustainable due to non-application of mind and lack of opportunity to represent against such retrospective action. The court directed that the cancellation shall take effect only from the date of issuance of the SCN, 27 June 2023. The petition was disposed of accordingly.
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