Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Retrospective cancellation of GST registration must be supported by specific contingencies, and both the show cause notice and the cancellation order must disclose the factual basis and reasons. Where the notice is silent on the grounds for retrospective action and the cancellation order is equally unreasoned, the proceedings are unsustainable for breach of the requirement of reasoned quasi-judicial action and fair hearing. Applying that principle, the High Court set aside the show cause notice, the order cancelling registration retrospectively, and the order rejecting revocation, while granting the authorities liberty to proceed afresh in accordance with law.
Retrospective cancellation of GST registration must be supported by specific contingencies, and both the show cause notice and the cancellation order must disclose the factual basis and reasons. Where the notice is silent on the grounds for retrospective action and the cancellation order is equally unreasoned, the proceedings are unsustainable for breach of the requirement of reasoned quasi-judicial action and fair hearing. Applying that principle, the High Court set aside the show cause notice, the order cancelling registration retrospectively, and the order rejecting revocation, while granting the authorities liberty to proceed afresh in accordance with law.
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