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 retrospective cancellation of the petitioner's GST registration was not justified as the show cause notice (SCN) did not contemplate such retrospective effect, nor were any reasons provided to support it. Consequently, the cancellation order was to take effect only from the date of the SCN, 4th April 2022. The petition was accordingly disposed of, affirming that the registration could not be annulled retrospectively based solely on the non-availability of the principal place of business at the time of the field visit.
The HC held that the retrospective cancellation of the petitioner's GST registration was not justified as the show cause notice (SCN) did not contemplate such retrospective effect, nor were any reasons provided to support it. Consequently, the cancellation order was to take effect only from the date of the SCN, 4th April 2022. The petition was accordingly disposed of, affirming that the registration could not be annulled retrospectively based solely on the non-availability of the principal place of business at the time of the field visit.
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