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 under Section 29(2)(d) was set aside because the cancellation order lacked any reasons and showed no application of mind, and the petitioner was not afforded a personal hearing, breaching principles of natural justice and equality before law. The appellate dismissal on limitation grounds was quashed in view of this primary infirmity and the matter remitted for fresh consideration; the petitioner was directed to be permitted to file a reply and for the adjudicating authority to decide afresh after hearing and taking the defence into account.
Cancellation of GST registration under Section 29(2)(d) was set aside because the cancellation order lacked any reasons and showed no application of mind, and the petitioner was not afforded a personal hearing, breaching principles of natural justice and equality before law. The appellate dismissal on limitation grounds was quashed in view of this primary infirmity and the matter remitted for fresh consideration; the petitioner was directed to be permitted to file a reply and for the adjudicating authority to decide afresh after hearing and taking the defence into account.
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