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...
HC dismissed the writ while noting the GST registration had been validly cancelled under the statutory provision for non-furnishing of returns for six continuous months and that an empowered officer may effect cancellation, including retrospectively, pursuant to the prescribed procedure. However, having regard to the proviso to the procedural rule and the serious civil consequences of cancellation, the HC held that if the petitioner approaches the competent officer within two months, furnishes all pending returns and pays the outstanding tax, interest and applicable late fees, the empowered officer retains jurisdiction to drop the proceedings and pass an appropriate restoration order in the prescribed form; the petition is disposed on those terms.
HC dismissed the writ while noting the GST registration had been validly cancelled under the statutory provision for non-furnishing of returns for six continuous months and that an empowered officer may effect cancellation, including retrospectively, pursuant to the prescribed procedure. However, having regard to the proviso to the procedural rule and the serious civil consequences of cancellation, the HC held that if the petitioner approaches the competent officer within two months, furnishes all pending returns and pays the outstanding tax, interest and applicable late fees, the empowered officer retains jurisdiction to drop the proceedings and pass an appropriate restoration order in the prescribed form; the petition is disposed on those terms.
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