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 backdated to 21 July 2017 and held the impugned rejection order invalid for lack of reasons. Noting the Petitioner had sought cancellation and that the SCN did not propose retrospective cancellation, the Court directed that cancellation, if sustained, shall operate only from the SCN date, 26 July 2023. The HC reaffirmed that authorities cannot impose retroactive cancellation absent explicit notice in the SCN. The GST authority remains free to initiate or continue any lawful proceedings for other violations against the Petitioner; the writ petition is disposed accordingly.
The HC set aside the retrospective cancellation of the Petitioner's GST registration backdated to 21 July 2017 and held the impugned rejection order invalid for lack of reasons. Noting the Petitioner had sought cancellation and that the SCN did not propose retrospective cancellation, the Court directed that cancellation, if sustained, shall operate only from the SCN date, 26 July 2023. The HC reaffirmed that authorities cannot impose retroactive cancellation absent explicit notice in the SCN. The GST authority remains free to initiate or continue any lawful proceedings for other violations against the Petitioner; the writ petition is disposed accordingly.
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