Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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GST registration cancellation could not stand where the original order was non-speaking and did not disclose the date, mode or manner of service of the show cause notice, despite service being disputed. Proceeding ex parte on an assumed service basis without recording those particulars rendered the cancellation order unsustainable, and it was set aside with remand for fresh decision after reply and hearing. The appellate order was also vitiated because the authority failed to consider the specific grounds for condonation of delay raised in the appeal memorandum and instead relied on assumptions not reflected in the appeal itself. That order too was set aside.
GST registration cancellation could not stand where the original order was non-speaking and did not disclose the date, mode or manner of service of the show cause notice, despite service being disputed. Proceeding ex parte on an assumed service basis without recording those particulars rendered the cancellation order unsustainable, and it was set aside with remand for fresh decision after reply and hearing. The appellate order was also vitiated because the authority failed to consider the specific grounds for condonation of delay raised in the appeal memorandum and instead relied on assumptions not reflected in the appeal itself. That order too was set aside.
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