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 held that the omission of Rule 89(4B) and Rule 96(10) of the CGST Rules by the 08.10.2024 notification operates to erase those provisions ab initio for all matters other than "transactions past and closed"; Section 6 of the General Clauses Act does not apply to the omission effected by subordinate Rules and no savings clause was afforded, nor does s.174(3) or the notification's commencement clause save pending matters. Consequentially, undisposed show-cause notices, orders issued after 08.10.2024, and pre-08.10.2024 orders not finally determined (including matters pending on appeal or review) have lapsed. The impugned show-cause notices and original orders are set aside and the petitions are disposed.
The HC held that the omission of Rule 89(4B) and Rule 96(10) of the CGST Rules by the 08.10.2024 notification operates to erase those provisions ab initio for all matters other than "transactions past and closed"; Section 6 of the General Clauses Act does not apply to the omission effected by subordinate Rules and no savings clause was afforded, nor does s.174(3) or the notification's commencement clause save pending matters. Consequentially, undisposed show-cause notices, orders issued after 08.10.2024, and pre-08.10.2024 orders not finally determined (including matters pending on appeal or review) have lapsed. The impugned show-cause notices and original orders are set aside and the petitions are disposed.
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