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 held the retrospective cancellation of the Petitioner's GST registration invalid because the impugned cancellation order dated 14 Nov 2020 bore no signature or digital signature as mandated by Rule 26(3) CGST Rules and the Respondents failed to discharge the onus of proving compliance; principles of natural justice were thereby infringed. The court found no evidence or sworn statement of a signed/digitally signed order, rejected inferential contentions, and declared the unsigned order to be no order in law until properly signed. Consequentially, the Appellate Authority's 28 Feb 2025 dismissal on limitation grounds shall not survive. Appeal disposed.
The HC held the retrospective cancellation of the Petitioner's GST registration invalid because the impugned cancellation order dated 14 Nov 2020 bore no signature or digital signature as mandated by Rule 26(3) CGST Rules and the Respondents failed to discharge the onus of proving compliance; principles of natural justice were thereby infringed. The court found no evidence or sworn statement of a signed/digitally signed order, rejected inferential contentions, and declared the unsigned order to be no order in law until properly signed. Consequentially, the Appellate Authority's 28 Feb 2025 dismissal on limitation grounds shall not survive. Appeal disposed.
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