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 quashed cancellation of GST registration and rejection of revocation because the show-cause notices and orders were non-speaking, lacked due consideration of the taxpayer's submissions, and were passed without affording a personal hearing. The Court held that cancellation of registration carries serious civil consequences and must comply with natural justice, including a reasoned decision. The impugned notices and consequential orders were set aside, and the matter was remanded to the original authority for fresh adjudication after hearing the petitioner and passing a speaking order.
HC quashed cancellation of GST registration and rejection of revocation because the show-cause notices and orders were non-speaking, lacked due consideration of the taxpayer's submissions, and were passed without affording a personal hearing. The Court held that cancellation of registration carries serious civil consequences and must comply with natural justice, including a reasoned decision. The impugned notices and consequential orders were set aside, and the matter was remanded to the original authority for fresh adjudication after hearing the petitioner and passing a speaking order.
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