Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Refund rejection without a reasonable opportunity to reply to the show-cause notice breached principles of natural justice. Although the Department had discretion to grant further time, that discretion had to be exercised fairly; where the taxpayer sought extension the next day to gather documents and file a reply, immediate rejection on expiry of a short period showed unwarranted haste. The impugned order was quashed, the taxpayer was given two weeks to file its reply with supporting documents, and the Department was left free to pass a fresh order thereafter.
Refund rejection without a reasonable opportunity to reply to the show-cause notice breached principles of natural justice. Although the Department had discretion to grant further time, that discretion had to be exercised fairly; where the taxpayer sought extension the next day to gather documents and file a reply, immediate rejection on expiry of a short period showed unwarranted haste. The impugned order was quashed, the taxpayer was given two weeks to file its reply with supporting documents, and the Department was left free to pass a fresh order thereafter.
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