Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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