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 set aside the impugned retrospective cancellation of the petitioner's GST registration and disposed of the petition. The court found the adjudicating authority failed to properly address the allegation of excess input tax credit and did not afford adequate consideration to the petitioner's written and oral explanations, raising natural justice concerns. Retrospective cancellation was held unsustainable in the absence of reasoned findings. The matter is remitted to the adjudicating authority to hear the petitioner, consider the stand on excess ITC, and pass a reasoned order addressing the petitioner's reply and oral submissions within a stipulated timeframe.
HC set aside the impugned retrospective cancellation of the petitioner's GST registration and disposed of the petition. The court found the adjudicating authority failed to properly address the allegation of excess input tax credit and did not afford adequate consideration to the petitioner's written and oral explanations, raising natural justice concerns. Retrospective cancellation was held unsustainable in the absence of reasoned findings. The matter is remitted to the adjudicating authority to hear the petitioner, consider the stand on excess ITC, and pass a reasoned order addressing the petitioner's reply and oral submissions within a stipulated timeframe.
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