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 exercised Article 226 writ jurisdiction to restore a cancelled GST registration, applying the revival framework laid down in the cited precedent Tvl. Suguna Cut Piece Center. The court required compliance with filing of returns, payment of tax, interest, fines and fees, imposed restrictions on utilisation of Input Tax Credit pending scrutiny, and directed other safeguards as conditions for revival. The petitioner's electronic credit ledger status and a second inspection informed the factual backdrop, and the writ petition was disposed of by directing revival on those specified conditions.
HC exercised Article 226 writ jurisdiction to restore a cancelled GST registration, applying the revival framework laid down in the cited precedent Tvl. Suguna Cut Piece Center. The court required compliance with filing of returns, payment of tax, interest, fines and fees, imposed restrictions on utilisation of Input Tax Credit pending scrutiny, and directed other safeguards as conditions for revival. The petitioner's electronic credit ledger status and a second inspection informed the factual backdrop, and the writ petition was disposed of by directing revival on those specified conditions.
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