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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Under GST, a personal hearing under Section 75(4) is required when a written request is made or when an adverse order is contemplated; the text states that this requirement was satisfied because the taxpayer was given three hearings after replying to the show cause notice, and its authorised representative treated the written defence as final at the last hearing. The challenge for denial of personal hearing was rejected, and a second hearing before the final adverse order was held unnecessary. The separate grievance on premature recovery was left open for further instructions.
Under GST, a personal hearing under Section 75(4) is required when a written request is made or when an adverse order is contemplated; the text states that this requirement was satisfied because the taxpayer was given three hearings after replying to the show cause notice, and its authorised representative treated the written defence as final at the last hearing. The challenge for denial of personal hearing was rejected, and a second hearing before the final adverse order was held unnecessary. The separate grievance on premature recovery was left open for further instructions.
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