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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The HC quashed cancellation of GST registration where the show-cause notice was cyclostyled, the authority ignored the taxpayer's reply, and the cancellation order departed from the notice without particulars. The Court held that such a mechanical exercise showed patent non-application of mind and failure to act in accordance with the statute. It also ruled that the availability of a statutory revocation remedy did not bar interference under Article 226 in these circumstances. The cancellation order was set aside and the GST registration restored.
The HC quashed cancellation of GST registration where the show-cause notice was cyclostyled, the authority ignored the taxpayer's reply, and the cancellation order departed from the notice without particulars. The Court held that such a mechanical exercise showed patent non-application of mind and failure to act in accordance with the statute. It also ruled that the availability of a statutory revocation remedy did not bar interference under Article 226 in these circumstances. The cancellation order was set aside and the GST registration restored.
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