Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Portal-only GST service may be inadequate where it does not provide effective notice of the complete show cause notice or reasoned order and thereby denies a meaningful opportunity to respond. Section 169 permits Common Portal availability as a mode of service, but Rule 142 distinguishes FORM GST DRC-01 and DRC-07 electronic summaries from the underlying notice or order. Section 75 requires a hearing where an adverse decision is contemplated and reasons in the adjudication order. Retrospective expansion of Common Portal functions does not by itself cure deficient communication. For appellate limitation, proof of upload or dispatch may not establish effective communication where accessibility, actual or constructive knowledge, or retrieval of the complete communication remains unproven.
Portal-only GST service may be inadequate where it does not provide effective notice of the complete show cause notice or reasoned order and thereby denies a meaningful opportunity to respond. Section 169 permits Common Portal availability as a mode of service, but Rule 142 distinguishes FORM GST DRC-01 and DRC-07 electronic summaries from the underlying notice or order. Section 75 requires a hearing where an adverse decision is contemplated and reasons in the adjudication order. Retrospective expansion of Common Portal functions does not by itself cure deficient communication. For appellate limitation, proof of upload or dispatch may not establish effective communication where accessibility, actual or constructive knowledge, or retrieval of the complete communication remains unproven.
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