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 for continuous non-filing of returns was set aside where the taxpayer was still carrying on taxable works contract activity and continued registration was necessary to ensure discharge of statutory tax liabilities. The Court held that excluding the taxpayer from the GST regime would prejudice revenue, because any dues payable under the GST law would otherwise remain outside the tax system. Following the approach adopted in similar matters, the authorities were directed to intimate the outstanding statutory dues up to the date of cancellation, and upon payment, to revoke the cancellation and restore registration.
Cancellation of GST registration for continuous non-filing of returns was set aside where the taxpayer was still carrying on taxable works contract activity and continued registration was necessary to ensure discharge of statutory tax liabilities. The Court held that excluding the taxpayer from the GST regime would prejudice revenue, because any dues payable under the GST law would otherwise remain outside the tax system. Following the approach adopted in similar matters, the authorities were directed to intimate the outstanding statutory dues up to the date of cancellation, and upon payment, to revoke the cancellation and restore registration.
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