Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Blocking of an electronic credit ledger carries civil consequences and, even where the authority has jurisdiction to act on suspected fraudulent availment of input tax credit, it must comply with natural justice. The HC noted that prior notice and an opportunity of hearing are required before such blocking. As the impugned order was issued without giving the affected person that opportunity, it was set aside. The authority was left free to commence fresh proceedings in accordance with law after due notice and hearing.
Blocking of an electronic credit ledger carries civil consequences and, even where the authority has jurisdiction to act on suspected fraudulent availment of input tax credit, it must comply with natural justice. The HC noted that prior notice and an opportunity of hearing are required before such blocking. As the impugned order was issued without giving the affected person that opportunity, it was set aside. The authority was left free to commence fresh proceedings in accordance with law after due notice and hearing.
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