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 with retrospective effect - SCN did not indicate reasons for cancelling registration ab initio - Violation of natural justice principles - Held: Impugned SCN did not propose adverse action of cancelling registration from date of grant. While proper officer can cancel registration with retrospective effect u/s 29(2) of CGST/DGST Act, such action cannot be arbitrary or whimsical and must be informed by cogent reasons. Impugned cancellation order passed in violation of natural justice and without reasons, liable to be set aside. However, cancellation order to be operative from date petitioner applied for cancellation of GST registration, not retrospectively from date of grant.
Cancellation of GST registration with retrospective effect - SCN did not indicate reasons for cancelling registration ab initio - Violation of natural justice principles - Held: Impugned SCN did not propose adverse action of cancelling registration from date of grant. While proper officer can cancel registration with retrospective effect u/s 29(2) of CGST/DGST Act, such action cannot be arbitrary or whimsical and must be informed by cogent reasons. Impugned cancellation order passed in violation of natural justice and without reasons, liable to be set aside. However, cancellation order to be operative from date petitioner applied for cancellation of GST registration, not retrospectively from date of grant.
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