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...
Retrospective cancellation of GST registration must be supported by specific contingencies, and both the show cause notice and the cancellation order must disclose the factual basis and reasons. Where the notice is silent on the grounds for retrospective action and the cancellation order is equally unreasoned, the proceedings are unsustainable for breach of the requirement of reasoned quasi-judicial action and fair hearing. Applying that principle, the High Court set aside the show cause notice, the order cancelling registration retrospectively, and the order rejecting revocation, while granting the authorities liberty to proceed afresh in accordance with law.
Retrospective cancellation of GST registration must be supported by specific contingencies, and both the show cause notice and the cancellation order must disclose the factual basis and reasons. Where the notice is silent on the grounds for retrospective action and the cancellation order is equally unreasoned, the proceedings are unsustainable for breach of the requirement of reasoned quasi-judicial action and fair hearing. Applying that principle, the High Court set aside the show cause notice, the order cancelling registration retrospectively, and the order rejecting revocation, while granting the authorities liberty to proceed afresh in accordance with law.
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