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 permanent cancellation of the petitioner's GST registration arising solely from belated filing of returns and non-payment, finding that such extreme sanction is not warranted where the petitioner can continue business and discharge statutory liabilities; the court noted the petitioner had, prima facie, remediated the default by paying assessed tax, interest and late fees. The respondents are directed to furnish written intimation within 15 days of upload of the order specifying any further penalty or dues payable by the petitioner; the petitioner shall remit any such demanded amounts within 15 days of receipt of that intimation. The petition is disposed.
The HC set aside the permanent cancellation of the petitioner's GST registration arising solely from belated filing of returns and non-payment, finding that such extreme sanction is not warranted where the petitioner can continue business and discharge statutory liabilities; the court noted the petitioner had, prima facie, remediated the default by paying assessed tax, interest and late fees. The respondents are directed to furnish written intimation within 15 days of upload of the order specifying any further penalty or dues payable by the petitioner; the petitioner shall remit any such demanded amounts within 15 days of receipt of that intimation. The petition is disposed.
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