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...
Cancellation of GST registration was upheld where registration was obtained to wrongfully avail input tax credit without proof of physical movement and genuineness; court found transactions were camouflaged by mantenering multiple registrations at the same premises, and that invoices were used to pass illegitimate ITC. The appellate order affirming cancellation was not interfered with for lack of justification in holding separate registrations for the same premises; consequence: the writ petition dismissed and respondents granted liberty to recover tax and penalty from customers.
Cancellation of GST registration was upheld where registration was obtained to wrongfully avail input tax credit without proof of physical movement and genuineness; court found transactions were camouflaged by mantenering multiple registrations at the same premises, and that invoices were used to pass illegitimate ITC. The appellate order affirming cancellation was not interfered with for lack of justification in holding separate registrations for the same premises; consequence: the writ petition dismissed and respondents granted liberty to recover tax and penalty from customers.
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