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...
Failure to file returns for a continuous period of six months...
GST registration cancelled retrospectively without reasons, violating natural justice. Cancellation order set aside. Proper officer's power not arbitrary.
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Failure to file returns for a continuous period of six months led to cancellation of GST registration. Cancellation order did not specify reasons for retrospective cancellation from registration date, violating principles of natural justice. Proper officer's power to cancel registration from a date cannot be arbitrary, must be informed by reason. Impugned order set aside, matter remanded to Appellate Authority to decide afresh on merits after providing opportunity of hearing, uninfluenced by delay question.
Failure to file returns for a continuous period of six months led to cancellation of GST registration. Cancellation order did not specify reasons for retrospective cancellation from registration date, violating principles of natural justice. Proper officer's power to cancel registration from a date cannot be arbitrary, must be informed by reason. Impugned order set aside, matter remanded to Appellate Authority to decide afresh on merits after providing opportunity of hearing, uninfluenced by delay question.
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