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...
GST registration cancellation requires the personal hearing mandated by Section 75(4), including fixation of at least three hearing dates. Revocation proceedings must consider returns and late fees uploaded before issuance of the notice; failure to do so indicates non-application of mind. A notice rejecting revocation should disclose the issuing officer's name and designation. Where a DIN was mandatory, a subsequent circular exempting portal-generated communications from DIN requirements cannot retrospectively validate a DIN-less notice. These requirements protect procedural fairness and the validity of registration cancellation and revocation actions.
GST registration cancellation requires the personal hearing mandated by Section 75(4), including fixation of at least three hearing dates. Revocation proceedings must consider returns and late fees uploaded before issuance of the notice; failure to do so indicates non-application of mind. A notice rejecting revocation should disclose the issuing officer's name and designation. Where a DIN was mandatory, a subsequent circular exempting portal-generated communications from DIN requirements cannot retrospectively validate a DIN-less notice. These requirements protect procedural fairness and the validity of registration cancellation and revocation actions.
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