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 dismissed the review insofar as it does not disturb the impugned cancellation of the Petitioner's GST registration and instead recorded systemic concerns about fictitious firms, impersonation and notarized affidavits executed without client verification. The Court observed recurring misuse of accountant/GST practitioner referrals to procure registrations in stolen identities and noted parallel findings in related matters. No adverse findings were made against the Advocate on record due to full disclosure of the referral chain. The Registry was directed to communicate this order to the Standing Counsel (Criminal) and to list the matter for further consideration on the specified date for procedural compliance and any remedial directions.
The HC dismissed the review insofar as it does not disturb the impugned cancellation of the Petitioner's GST registration and instead recorded systemic concerns about fictitious firms, impersonation and notarized affidavits executed without client verification. The Court observed recurring misuse of accountant/GST practitioner referrals to procure registrations in stolen identities and noted parallel findings in related matters. No adverse findings were made against the Advocate on record due to full disclosure of the referral chain. The Registry was directed to communicate this order to the Standing Counsel (Criminal) and to list the matter for further consideration on the specified date for procedural compliance and any remedial directions.
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