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, exercising jurisdiction under Article 226, entertained the writ petition despite expiry of the statutory appeal period and grace period, holding that the impugned cancellation of the Petitioner's GST registration resulted from curable procedural non-compliance and that substantive rights should not be defeated by formal irregularities; the Court observed that alternative remedies are not an absolute bar to constitutional relief and that equitable considerations favor restoration to enable revenue realization. The impugned cancellation order is set aside and quashed, the writ petition is allowed, and the Petitioner's GST registration is to be restored so it may resume business.
The HC, exercising jurisdiction under Article 226, entertained the writ petition despite expiry of the statutory appeal period and grace period, holding that the impugned cancellation of the Petitioner's GST registration resulted from curable procedural non-compliance and that substantive rights should not be defeated by formal irregularities; the Court observed that alternative remedies are not an absolute bar to constitutional relief and that equitable considerations favor restoration to enable revenue realization. The impugned cancellation order is set aside and quashed, the writ petition is allowed, and the Petitioner's GST registration is to be restored so it may resume business.
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