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 that the impugned show cause notice for cancellation of registration lacked the requisite ingredients of a proper SCN as mandated by Form GST REG-17 u/r 22(1), resulting in a serious violation of the principles of natural justice since no definite date or time was specified, preventing the petitioner from making an effective defence. Consequently, the SCN dated 17.03.2025, the order of cancellation dated 28.03.2025 and the order rejecting the revocation application dated 11.06.2025 were set aside. Liberty was reserved to the respondents to institute fresh cancellation proceedings, if lawful grounds exist, in accordance with applicable statutory procedure.
The HC held that the impugned show cause notice for cancellation of registration lacked the requisite ingredients of a proper SCN as mandated by Form GST REG-17 u/r 22(1), resulting in a serious violation of the principles of natural justice since no definite date or time was specified, preventing the petitioner from making an effective defence. Consequently, the SCN dated 17.03.2025, the order of cancellation dated 28.03.2025 and the order rejecting the revocation application dated 11.06.2025 were set aside. Liberty was reserved to the respondents to institute fresh cancellation proceedings, if lawful grounds exist, in accordance with applicable statutory procedure.
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