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...
Defective SCN - The High court observed that the show cause notice lacked clarity regarding the grounds of alleged violation and did not contain essential details such as the name, designation, or signature of the issuing authority. - It noted that although the notice mentioned attached supporting documents, none were actually attached. - The court further highlighted that the Form GST REG 31 produced by the respondents did not serve as a proper show cause notice for cancellation of registration. - The court set aside both the show cause notice and Form GST REG 31, emphasizing that the respondents could issue a proper notice in accordance with the law if necessary.
Defective SCN - The High court observed that the show cause notice lacked clarity regarding the grounds of alleged violation and did not contain essential details such as the name, designation, or signature of the issuing authority. - It noted that although the notice mentioned attached supporting documents, none were actually attached. - The court further highlighted that the Form GST REG 31 produced by the respondents did not serve as a proper show cause notice for cancellation of registration. - The court set aside both the show cause notice and Form GST REG 31, emphasizing that the respondents could issue a proper notice in accordance with the law if necessary.
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