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 held that the impugned show cause notice for cancellation of registration lacked the requisite ingredients of a proper SCN as mandated by Form GST REG-17 u/r 22(1), resulting in a serious violation of the principles of natural justice since no definite date or time was specified, preventing the petitioner from making an effective defence. Consequently, the SCN dated 17.03.2025, the order of cancellation dated 28.03.2025 and the order rejecting the revocation application dated 11.06.2025 were set aside. Liberty was reserved to the respondents to institute fresh cancellation proceedings, if lawful grounds exist, in accordance with applicable statutory procedure.
The HC held that the impugned show cause notice for cancellation of registration lacked the requisite ingredients of a proper SCN as mandated by Form GST REG-17 u/r 22(1), resulting in a serious violation of the principles of natural justice since no definite date or time was specified, preventing the petitioner from making an effective defence. Consequently, the SCN dated 17.03.2025, the order of cancellation dated 28.03.2025 and the order rejecting the revocation application dated 11.06.2025 were set aside. Liberty was reserved to the respondents to institute fresh cancellation proceedings, if lawful grounds exist, in accordance with applicable statutory procedure.
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