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 text addresses cancellation of GST registration for alleged fraudulent input tax credit and the validity of a show cause notice. It holds that a notice referring only to statutory provisions without specifying transactions or factual basis fails to disclose reasons and cannot sustain cancellation; accordingly the defective notice and consequent cancellation were set aside. Simultaneously, on prima facie material of large scale fraud the authorities were authorised to issue a fresh show cause notice and complete time bound adjudication; an interim stay was continued for six weeks and registration must be restored if proceedings are not concluded for reasons not attributable to the registrant.
The text addresses cancellation of GST registration for alleged fraudulent input tax credit and the validity of a show cause notice. It holds that a notice referring only to statutory provisions without specifying transactions or factual basis fails to disclose reasons and cannot sustain cancellation; accordingly the defective notice and consequent cancellation were set aside. Simultaneously, on prima facie material of large scale fraud the authorities were authorised to issue a fresh show cause notice and complete time bound adjudication; an interim stay was continued for six weeks and registration must be restored if proceedings are not concluded for reasons not attributable to the registrant.
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