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 set aside the impugned retrospective cancellation of the petitioner's GST registration and disposed of the petition. The court found the adjudicating authority failed to properly address the allegation of excess input tax credit and did not afford adequate consideration to the petitioner's written and oral explanations, raising natural justice concerns. Retrospective cancellation was held unsustainable in the absence of reasoned findings. The matter is remitted to the adjudicating authority to hear the petitioner, consider the stand on excess ITC, and pass a reasoned order addressing the petitioner's reply and oral submissions within a stipulated timeframe.
HC set aside the impugned retrospective cancellation of the petitioner's GST registration and disposed of the petition. The court found the adjudicating authority failed to properly address the allegation of excess input tax credit and did not afford adequate consideration to the petitioner's written and oral explanations, raising natural justice concerns. Retrospective cancellation was held unsustainable in the absence of reasoned findings. The matter is remitted to the adjudicating authority to hear the petitioner, consider the stand on excess ITC, and pass a reasoned order addressing the petitioner's reply and oral submissions within a stipulated timeframe.
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