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 for non filing of returns may be dropped where the registered person furnishes all pending returns and pays tax, interest and late fee as required by the proviso to Rule 22(4); the proper officer is empowered to pass FORM GST REG 20 and consider restoration of GST registration upon such compliance. The petitioner was directed to apply within the prescribed period and, on compliance, the authority shall expeditiously consider restoration. Computation of limitation under Section 73(10) runs from this order, with the financial year 2024 25 governed by Section 44.
Cancellation for non filing of returns may be dropped where the registered person furnishes all pending returns and pays tax, interest and late fee as required by the proviso to Rule 22(4); the proper officer is empowered to pass FORM GST REG 20 and consider restoration of GST registration upon such compliance. The petitioner was directed to apply within the prescribed period and, on compliance, the authority shall expeditiously consider restoration. Computation of limitation under Section 73(10) runs from this order, with the financial year 2024 25 governed by Section 44.
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