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 cancellation of GST registration under Section 29(2)(c) for non-filing of returns for six continuous months must adhere to the procedural safeguards under Rule 22 of the CGST Rules, 2017. The petitioner's registration was cancelled without reasons, violating natural justice. The Court observed that if the petitioner, upon receiving a show cause notice, is willing to submit all pending returns and pay tax dues with interest and late fees, the empowered officer may drop cancellation proceedings and restore registration by issuing Form GST REG-20. The writ petition was disposed of with a direction that the petitioner approach the appropriate authority within two months to seek restoration of GST registration by fulfilling these conditions.
The HC held that cancellation of GST registration under Section 29(2)(c) for non-filing of returns for six continuous months must adhere to the procedural safeguards under Rule 22 of the CGST Rules, 2017. The petitioner's registration was cancelled without reasons, violating natural justice. The Court observed that if the petitioner, upon receiving a show cause notice, is willing to submit all pending returns and pay tax dues with interest and late fees, the empowered officer may drop cancellation proceedings and restore registration by issuing Form GST REG-20. The writ petition was disposed of with a direction that the petitioner approach the appropriate authority within two months to seek restoration of GST registration by fulfilling these conditions.
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