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...
GST registration cancellation could not stand where the original order was non-speaking and did not disclose the date, mode or manner of service of the show cause notice, despite service being disputed. Proceeding ex parte on an assumed service basis without recording those particulars rendered the cancellation order unsustainable, and it was set aside with remand for fresh decision after reply and hearing. The appellate order was also vitiated because the authority failed to consider the specific grounds for condonation of delay raised in the appeal memorandum and instead relied on assumptions not reflected in the appeal itself. That order too was set aside.
GST registration cancellation could not stand where the original order was non-speaking and did not disclose the date, mode or manner of service of the show cause notice, despite service being disputed. Proceeding ex parte on an assumed service basis without recording those particulars rendered the cancellation order unsustainable, and it was set aside with remand for fresh decision after reply and hearing. The appellate order was also vitiated because the authority failed to consider the specific grounds for condonation of delay raised in the appeal memorandum and instead relied on assumptions not reflected in the appeal itself. That order too was set aside.
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