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 allowed the writ in part, holding that retrospective cancellation of the GST registration was unsustainable where the SCN did not propose retrospective cancellation; accordingly the cancellation shall take effect from the date of issuance of the SCN (2 February 2022). The Court observed that, despite delay, it would entertain the petition due to intervening circumstances including the death of a partner and dissolution of the firm. The HC concluded that principles of natural justice were not breached in a manner warranting retrospective relief and disposed of the petition, directing that the impugned order operate prospectively from the SCN date.
The HC allowed the writ in part, holding that retrospective cancellation of the GST registration was unsustainable where the SCN did not propose retrospective cancellation; accordingly the cancellation shall take effect from the date of issuance of the SCN (2 February 2022). The Court observed that, despite delay, it would entertain the petition due to intervening circumstances including the death of a partner and dissolution of the firm. The HC concluded that principles of natural justice were not breached in a manner warranting retrospective relief and disposed of the petition, directing that the impugned order operate prospectively from the SCN date.
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