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 for continuous non-furnishing of returns is authorised where an empowered officer may cancel registration from an appropriate date; Rule 22 procedure and its proviso permit restoration if the registrant furnishes all pending returns and pays tax, interest and late fees. The court directed the petitioner to apply to the authority within two months for restoration; the authority may drop proceedings and pass the prescribed form order (REG-20) on compliance. The registrant remains liable for arrears and the order is confined to the case facts.
Cancellation of GST registration for continuous non-furnishing of returns is authorised where an empowered officer may cancel registration from an appropriate date; Rule 22 procedure and its proviso permit restoration if the registrant furnishes all pending returns and pays tax, interest and late fees. The court directed the petitioner to apply to the authority within two months for restoration; the authority may drop proceedings and pass the prescribed form order (REG-20) on compliance. The registrant remains liable for arrears and the order is confined to the case facts.
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