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...
The HC set aside the retrospective cancellation of the petitioner's GST registration for noncompliance with Rule 10A CGST Rules and for lack of a reasoned order under Section 29(2), holding that retrospective revocation requires a show-cause notice contemplating such effect and a reasoned application of mind. The court directed that the cancellation shall be effective only from the date of issuance of the SCN, namely 6 August 2024, while permitting the revenue to initiate further proceedings if it intends to pursue retrospective cancellation in accordance with law. The petition is disposed of.
The HC set aside the retrospective cancellation of the petitioner's GST registration for noncompliance with Rule 10A CGST Rules and for lack of a reasoned order under Section 29(2), holding that retrospective revocation requires a show-cause notice contemplating such effect and a reasoned application of mind. The court directed that the cancellation shall be effective only from the date of issuance of the SCN, namely 6 August 2024, while permitting the revenue to initiate further proceedings if it intends to pursue retrospective cancellation in accordance with law. The petition is disposed of.
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