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...
Retrospective cancellation of GST registration was challenged due to lack of adequate reasons provided for cancellation and violation of principles of natural justice. The High Court, relying on Riddhi Siddhi Enterprises case, held that authorities failed to assign even rudimentary reasons for retroactive cancellation, rendering the order unsustainable. Additionally, the original show cause notice did not indicate intention for retrospective cancellation. Consequently, the impugned order was quashed to the extent of retrospective effect from 12 November 2019. The cancellation was allowed prospectively from 09 September 2022, the date of show cause notice issuance, upholding principles of natural justice.
Retrospective cancellation of GST registration was challenged due to lack of adequate reasons provided for cancellation and violation of principles of natural justice. The High Court, relying on Riddhi Siddhi Enterprises case, held that authorities failed to assign even rudimentary reasons for retroactive cancellation, rendering the order unsustainable. Additionally, the original show cause notice did not indicate intention for retrospective cancellation. Consequently, the impugned order was quashed to the extent of retrospective effect from 12 November 2019. The cancellation was allowed prospectively from 09 September 2022, the date of show cause notice issuance, upholding principles of natural justice.
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