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 set aside the retrospective cancellation of the Petitioner's GST registration and quashed the impugned cancellation order, holding that retrospective cancellation is impermissible where the show cause notice did not contemplate retrospective effect; consequently the Petitioner's registration stands restored. The Court dismissed the ground for amendment rejection without prejudicing the Department's statutory rights, permitting the Revenue to initiate fresh proceedings or issue a fresh show cause notice if material emerges establishing non-existence of the taxable person or other legitimate grounds for cancellation. The petition is disposed of with the above directions and without any order as to costs.
The HC set aside the retrospective cancellation of the Petitioner's GST registration and quashed the impugned cancellation order, holding that retrospective cancellation is impermissible where the show cause notice did not contemplate retrospective effect; consequently the Petitioner's registration stands restored. The Court dismissed the ground for amendment rejection without prejudicing the Department's statutory rights, permitting the Revenue to initiate fresh proceedings or issue a fresh show cause notice if material emerges establishing non-existence of the taxable person or other legitimate grounds for cancellation. The petition is disposed of with the above directions and without any order as to costs.
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