Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Cancellation of GST Registration - Legal Validity of Retrospective Cancellation - The court acknowledged the lack of clarity in the show cause notice and the absence of sufficient reasons provided for the retrospective cancellation of GST registration. Emphasizing the importance of objective criteria for cancellation, the court ruled that cancellation cannot be automatic and must be based on justified grounds. Considering the petitioner's cessation of business and compliance until August 2021, the court modified the impugned order. The GST registration was deemed cancelled from the date of the show cause notice, providing relief to the petitioner.
Cancellation of GST Registration - Legal Validity of Retrospective Cancellation - The court acknowledged the lack of clarity in the show cause notice and the absence of sufficient reasons provided for the retrospective cancellation of GST registration. Emphasizing the importance of objective criteria for cancellation, the court ruled that cancellation cannot be automatic and must be based on justified grounds. Considering the petitioner's cessation of business and compliance until August 2021, the court modified the impugned order. The GST registration was deemed cancelled from the date of the show cause notice, providing relief to the petitioner.
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