Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The HC quashed the GST registration cancellation order and penalty imposed on the petitioner for non-filing of returns from April 2023 to February 2025. The court held that the administrative authority's rejection of the petitioner's delay condonation application violated principles of natural justice by failing to provide reasons or opportunity of hearing. Emphasizing that reasons constitute the heartbeat of every conclusion, the court ruled that orders without valid reasons are legally unsustainable and amount to denial of justice. The absence of reasoning renders administrative decisions arbitrary and subject to judicial review. The matter was remanded to the Appellate Authority with directions to conduct de-novo proceedings and pass a reasoned order after affording due hearing opportunity to the petitioner.
The HC quashed the GST registration cancellation order and penalty imposed on the petitioner for non-filing of returns from April 2023 to February 2025. The court held that the administrative authority's rejection of the petitioner's delay condonation application violated principles of natural justice by failing to provide reasons or opportunity of hearing. Emphasizing that reasons constitute the heartbeat of every conclusion, the court ruled that orders without valid reasons are legally unsustainable and amount to denial of justice. The absence of reasoning renders administrative decisions arbitrary and subject to judicial review. The matter was remanded to the Appellate Authority with directions to conduct de-novo proceedings and pass a reasoned order after affording due hearing opportunity to the petitioner.
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