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 petitioner's registration occurred without availing appellate remedy or Amnesty Scheme. SCN not produced in writ petition, nor averment of non-receipt, violating principles of natural justice. Section 30 of GST Act allows application for revocation within thirty days. Government issued Amnesty Scheme Circular No. 3 of 2023 permitting restoration of cancelled registrations on payment of dues between 31.03.2023 to 31.08.2023, which petitioner did not avail. Petitioner not a registered dealer after cancellation, with no monitoring by Department during intervening period, unable to ascertain transactions. Petitioner failed to utilize appellate remedy or Amnesty Scheme. Writ petition dismissed.
Cancellation of petitioner's registration occurred without availing appellate remedy or Amnesty Scheme. SCN not produced in writ petition, nor averment of non-receipt, violating principles of natural justice. Section 30 of GST Act allows application for revocation within thirty days. Government issued Amnesty Scheme Circular No. 3 of 2023 permitting restoration of cancelled registrations on payment of dues between 31.03.2023 to 31.08.2023, which petitioner did not avail. Petitioner not a registered dealer after cancellation, with no monitoring by Department during intervening period, unable to ascertain transactions. Petitioner failed to utilize appellate remedy or Amnesty Scheme. Writ petition dismissed.
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