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 requires an adequate opportunity of hearing, not merely a formal chance to respond. The High Court found that the authority fixed a personal hearing before the 30-day reply period had expired and cancelled the registration the next day, which showed undue haste and breached natural justice. The cancellation order was set aside for want of a fair and reasoned decision. The show cause notice was revived, and the competent authority was directed to take the petitioner's reply, grant hearing, and pass a speaking order.
GST registration cancellation requires an adequate opportunity of hearing, not merely a formal chance to respond. The High Court found that the authority fixed a personal hearing before the 30-day reply period had expired and cancelled the registration the next day, which showed undue haste and breached natural justice. The cancellation order was set aside for want of a fair and reasoned decision. The show cause notice was revived, and the competent authority was directed to take the petitioner's reply, grant hearing, and pass a speaking order.
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