Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Section 75(4) requires a personal hearing where an adverse decision is contemplated, and a show-cause notice for short-paid GST indicates such contemplation without requiring a separate written request. An assessment order issued without considering the taxpayer's reply, despite the reply and hearing request being on record, reflects non-application of mind. The assessment order was set aside, with fresh proceedings permitted from consideration of the reply after granting a personal hearing in accordance with law. Exemplary costs were directed against the respondent authority for treating the matter as though no reply had been filed.
Section 75(4) requires a personal hearing where an adverse decision is contemplated, and a show-cause notice for short-paid GST indicates such contemplation without requiring a separate written request. An assessment order issued without considering the taxpayer's reply, despite the reply and hearing request being on record, reflects non-application of mind. The assessment order was set aside, with fresh proceedings permitted from consideration of the reply after granting a personal hearing in accordance with law. Exemplary costs were directed against the respondent authority for treating the matter as though no reply had been filed.
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