Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
A show cause notice for cancellation of GST registration must disclose the precise default so the registrant can mount an effective reply. Here, the notice only referred to non-filing of returns for six months without identifying the relevant period, and the cancellation order failed to give specific reasons, making it a non-speaking order contrary to Rule 22(3), Form GST REG-19, and natural justice. The petitioner's failure to reply did not excuse the Proper Officer from passing a reasoned order. Despite delay in approaching the Court, the statutory defect in recording reasons prevailed. The cancellation order was quashed, and the matter was remitted to the notice stage for fresh consideration.
A show cause notice for cancellation of GST registration must disclose the precise default so the registrant can mount an effective reply. Here, the notice only referred to non-filing of returns for six months without identifying the relevant period, and the cancellation order failed to give specific reasons, making it a non-speaking order contrary to Rule 22(3), Form GST REG-19, and natural justice. The petitioner's failure to reply did not excuse the Proper Officer from passing a reasoned order. Despite delay in approaching the Court, the statutory defect in recording reasons prevailed. The cancellation order was quashed, and the matter was remitted to the notice stage for fresh consideration.
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