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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Natural justice requires disclosure of relied-upon inspection material before deciding revocation of GST registration cancellation. The Court directed the authorities to furnish the inspection material, the director's letters, and the Chartered Accountant's letter through proper channel, allow the petitioner to file a supplementary reply, hear the petitioner, and then decide the pending revocation application. It also directed adjudication of the pending DRC-01 proceedings for the relevant tax period. No final determination on the merits of the cancellation was made; the operative emphasis was on a fair opportunity to meet the material relied upon before orders are passed.
Natural justice requires disclosure of relied-upon inspection material before deciding revocation of GST registration cancellation. The Court directed the authorities to furnish the inspection material, the director's letters, and the Chartered Accountant's letter through proper channel, allow the petitioner to file a supplementary reply, hear the petitioner, and then decide the pending revocation application. It also directed adjudication of the pending DRC-01 proceedings for the relevant tax period. No final determination on the merits of the cancellation was made; the operative emphasis was on a fair opportunity to meet the material relied upon before orders are passed.
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