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 petitioner - The High Court acknowledges that the show cause notice was served solely through the portal and not through other means such as email or letter. Considering the petitioner's lack of familiarity with the system and the failure of their previous accountant to inform them about the non-filing of returns, the Court finds merit in the petitioner's argument. The Court notes that the cancellation occurred without giving the petitioner an opportunity to be heard, which is against the principles of natural justice. - The Court considers the petitioner's personal circumstances and directs them to file an appeal within 30 days, ensuring the appeal is entertained without considering the issue of limitation.
Cancellation of GST registration of petitioner - The High Court acknowledges that the show cause notice was served solely through the portal and not through other means such as email or letter. Considering the petitioner's lack of familiarity with the system and the failure of their previous accountant to inform them about the non-filing of returns, the Court finds merit in the petitioner's argument. The Court notes that the cancellation occurred without giving the petitioner an opportunity to be heard, which is against the principles of natural justice. - The Court considers the petitioner's personal circumstances and directs them to file an appeal within 30 days, ensuring the appeal is entertained without considering the issue of limitation.
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