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 held that the cancellation of the petitioner's registration was invalid due to violation of natural justice, specifically the failure to grant an opportunity of hearing and non-application of mind. Despite the petitioner submitting a reply, the order incorrectly stated no reply was received, indicating a lack of proper consideration. The court found the impugned order arbitrary and not meeting the standards of Article 14 of the Constitution. Consequently, the HC quashed the cancellation order and allowed the petition.
The HC held that the cancellation of the petitioner's registration was invalid due to violation of natural justice, specifically the failure to grant an opportunity of hearing and non-application of mind. Despite the petitioner submitting a reply, the order incorrectly stated no reply was received, indicating a lack of proper consideration. The court found the impugned order arbitrary and not meeting the standards of Article 14 of the Constitution. Consequently, the HC quashed the cancellation order and allowed the petition.
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