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 impugned order effectuating retrospective cancellation of the Petitioner's GST registration exceeded the scope of the show-cause notice and violated the audi alteram partem principle by failing to put the Petitioner on notice of retrospective de-registration. Consequently, the cancellation order was quashed insofar as it operated retrospectively, and the HC confined the effective date of cancellation to 31 December 2024, being the date of issuance of the show-cause notice. The petition was allowed and the Petitioner's registration is preserved up to that date, with liberty to contest any further proceedings in accordance with statutory procedure.
The HC held that the impugned order effectuating retrospective cancellation of the Petitioner's GST registration exceeded the scope of the show-cause notice and violated the audi alteram partem principle by failing to put the Petitioner on notice of retrospective de-registration. Consequently, the cancellation order was quashed insofar as it operated retrospectively, and the HC confined the effective date of cancellation to 31 December 2024, being the date of issuance of the show-cause notice. The petition was allowed and the Petitioner's registration is preserved up to that date, with liberty to contest any further proceedings in accordance with statutory procedure.
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