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 permitted the petitioner, whose registration certificate and SCN had been cancelled for non-filing of returns for six continuous months, to file all pending returns within eight weeks, noting deposit of substantial outstanding tax with interest and fees. The petitioner must execute an undertaking to comply with the GST Act and Rules and to file returns punctually; failure will result in automatic cancellation of registration. The respondents are directed to suspend the cancellation, consider the returns filed, and, if found in accordance with law, require payment of any remaining dues; upon payment as directed, the cancellation order shall be revoked. Petition is disposed of.
HC permitted the petitioner, whose registration certificate and SCN had been cancelled for non-filing of returns for six continuous months, to file all pending returns within eight weeks, noting deposit of substantial outstanding tax with interest and fees. The petitioner must execute an undertaking to comply with the GST Act and Rules and to file returns punctually; failure will result in automatic cancellation of registration. The respondents are directed to suspend the cancellation, consider the returns filed, and, if found in accordance with law, require payment of any remaining dues; upon payment as directed, the cancellation order shall be revoked. Petition is disposed of.
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