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 granted relief to the Petitioner seeking restoration of cancelled GST registration, noting petitioner has paid principal dues, interest and late fees and that analogous authorities favoured restoration where both revenue and taxable person benefit. The court declined to withhold relief merely because the revenue did not expressly consent, holding material facts align with precedents. The Respondents are directed to notify within 15 days of upload whether any further penalties or dues are payable; the Petitioner must remit any such demanded amounts within 15 days of receipt of that intimation. Petition disposed of on the stated terms.
The HC granted relief to the Petitioner seeking restoration of cancelled GST registration, noting petitioner has paid principal dues, interest and late fees and that analogous authorities favoured restoration where both revenue and taxable person benefit. The court declined to withhold relief merely because the revenue did not expressly consent, holding material facts align with precedents. The Respondents are directed to notify within 15 days of upload whether any further penalties or dues are payable; the Petitioner must remit any such demanded amounts within 15 days of receipt of that intimation. Petition disposed of on the stated terms.
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