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 set aside the retrospective cancellation of the petitioner's GST registration for noncompliance with Rule 10A CGST Rules and for lack of a reasoned order under Section 29(2), holding that retrospective revocation requires a show-cause notice contemplating such effect and a reasoned application of mind. The court directed that the cancellation shall be effective only from the date of issuance of the SCN, namely 6 August 2024, while permitting the revenue to initiate further proceedings if it intends to pursue retrospective cancellation in accordance with law. The petition is disposed of.
The HC set aside the retrospective cancellation of the petitioner's GST registration for noncompliance with Rule 10A CGST Rules and for lack of a reasoned order under Section 29(2), holding that retrospective revocation requires a show-cause notice contemplating such effect and a reasoned application of mind. The court directed that the cancellation shall be effective only from the date of issuance of the SCN, namely 6 August 2024, while permitting the revenue to initiate further proceedings if it intends to pursue retrospective cancellation in accordance with law. The petition is disposed of.
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