Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Vagueness in a show-cause notice and failure to disclose material particulars violated natural justice: cancellation of GST registration must rest on objective satisfaction of jurisdictional facts and independent quasi-judicial reasoning, not on investigative dictation. A non-speaking order repeating investigative allegations without identifying tax periods, invoices, suppliers or quantification is invalid. Consequently the impugned notices and cancellation orders were set aside and the petitioner's registration restored; the authority may, if advised, issue a fresh detailed show-cause notice specifying precise allegations, periods, invoices, suppliers and quantification and afford a reasonable hearing.
Vagueness in a show-cause notice and failure to disclose material particulars violated natural justice: cancellation of GST registration must rest on objective satisfaction of jurisdictional facts and independent quasi-judicial reasoning, not on investigative dictation. A non-speaking order repeating investigative allegations without identifying tax periods, invoices, suppliers or quantification is invalid. Consequently the impugned notices and cancellation orders were set aside and the petitioner's registration restored; the authority may, if advised, issue a fresh detailed show-cause notice specifying precise allegations, periods, invoices, suppliers and quantification and afford a reasonable hearing.
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