Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Cancellation of GST registration of the Petitioner with retrospective effect - The High court noted that the Show Cause Notice and the order of cancellation did not specify cogent reasons for the retrospective cancellation of registration. The court observed that under Section 29(2) of the Central Goods and Services Tax Act, 2017, the proper officer may cancel GST registration from a retrospective date if deemed fit, but such satisfaction must be based on objective criteria and cannot be subjective.
Cancellation of GST registration of the Petitioner with retrospective effect - The High court noted that the Show Cause Notice and the order of cancellation did not specify cogent reasons for the retrospective cancellation of registration. The court observed that under Section 29(2) of the Central Goods and Services Tax Act, 2017, the proper officer may cancel GST registration from a retrospective date if deemed fit, but such satisfaction must be based on objective criteria and cannot be subjective.
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