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 retrospective GST registration cancellation due to procedural deficiencies in the show cause notice (SCN). The notice failed to indicate any intention of retrospective cancellation or provide supporting reasons, violating principles of natural justice. The Court determined that the absence of prior notice regarding retrospective action and lack of justification rendered the cancellation order legally unsustainable. Consequently, the Court modified the cancellation to take effect prospectively from the SCN date (28 March 2023) rather than retrospectively. The ruling emphasizes the requirement for proper disclosure and reasoning in administrative orders affecting taxpayer rights under GST framework.
HC invalidated retrospective GST registration cancellation due to procedural deficiencies in the show cause notice (SCN). The notice failed to indicate any intention of retrospective cancellation or provide supporting reasons, violating principles of natural justice. The Court determined that the absence of prior notice regarding retrospective action and lack of justification rendered the cancellation order legally unsustainable. Consequently, the Court modified the cancellation to take effect prospectively from the SCN date (28 March 2023) rather than retrospectively. The ruling emphasizes the requirement for proper disclosure and reasoning in administrative orders affecting taxpayer rights under GST framework.
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