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...
Retrospective cancellation of GST registration requires a prior, specific proposal for retrospective effect in the show-cause notice and disclosure of the reasons/materials relied upon; absence of such proposal renders retrospective effect unsustainable. Authorities must supply any supportive documents referred to in the notice before final adjudication; failure to supply vitiates proceedings. Cancellation orders must be reasoned and not cryptic; non-speaking orders demonstrate non-application of mind and are unsustainable. Procedural defects of these kinds may justify exercise of extraordinary writ jurisdiction despite alternate remedies. Orders quashed with liberty to reopen proceedings after fresh notice, supply of materials and a reasoned hearing.
Retrospective cancellation of GST registration requires a prior, specific proposal for retrospective effect in the show-cause notice and disclosure of the reasons/materials relied upon; absence of such proposal renders retrospective effect unsustainable. Authorities must supply any supportive documents referred to in the notice before final adjudication; failure to supply vitiates proceedings. Cancellation orders must be reasoned and not cryptic; non-speaking orders demonstrate non-application of mind and are unsustainable. Procedural defects of these kinds may justify exercise of extraordinary writ jurisdiction despite alternate remedies. Orders quashed with liberty to reopen proceedings after fresh notice, supply of materials and a reasoned hearing.
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