Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Failure to consider a taxpayer's reply to a GST show-cause notice and to provide a hearing before an adverse determination breaches statutory requirements and principles of natural justice. Section 75(4) requires an opportunity of hearing where an adverse decision is contemplated, even without a written request. The GST determination, related demand proceedings and consequential appellate rejection were therefore set aside as unsustainable. The assessing authority may issue an appropriate notice and proceed in accordance with law.
Failure to consider a taxpayer's reply to a GST show-cause notice and to provide a hearing before an adverse determination breaches statutory requirements and principles of natural justice. Section 75(4) requires an opportunity of hearing where an adverse decision is contemplated, even without a written request. The GST determination, related demand proceedings and consequential appellate rejection were therefore set aside as unsustainable. The assessing authority may issue an appropriate notice and proceed in accordance with law.
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