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...
HC invalidated the retrospective cancellation of GST registration due to procedural deficiencies in the show cause notice (SCN). The original SCN failed to disclose the intent for retrospective cancellation or provide supporting reasons, violating principles of natural justice. The Court determined that absence of prior notice regarding retrospective action rendered the cancellation order invalid from February 13, 2024. While upholding the cancellation itself, the Court modified the effective date to align with the SCN issuance date of November 7, 2024, ensuring procedural fairness and due process in administrative action.
HC invalidated the retrospective cancellation of GST registration due to procedural deficiencies in the show cause notice (SCN). The original SCN failed to disclose the intent for retrospective cancellation or provide supporting reasons, violating principles of natural justice. The Court determined that absence of prior notice regarding retrospective action rendered the cancellation order invalid from February 13, 2024. While upholding the cancellation itself, the Court modified the effective date to align with the SCN issuance date of November 7, 2024, ensuring procedural fairness and due process in administrative action.
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