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...
Fresh GST proceedings under Section 74 may be initiated within two years from communication of an earlier writ order that quashed a prior notice while expressly permitting fresh action, provided fraud, wilful misstatement or suppression of facts to evade tax exists. Section 75(3), read with that binding direction, preserves the period for consequential adjudication; an earlier dropped Section 73 notice does not bar the fresh proceedings. However, a show cause notice containing unnecessary accusations that the taxpayer misled the Court demonstrates prejudgment and breaches the requirement of neutral adjudication. Such a notice must be set aside, with any fresh action undertaken by a different officer.
Fresh GST proceedings under Section 74 may be initiated within two years from communication of an earlier writ order that quashed a prior notice while expressly permitting fresh action, provided fraud, wilful misstatement or suppression of facts to evade tax exists. Section 75(3), read with that binding direction, preserves the period for consequential adjudication; an earlier dropped Section 73 notice does not bar the fresh proceedings. However, a show cause notice containing unnecessary accusations that the taxpayer misled the Court demonstrates prejudgment and breaches the requirement of neutral adjudication. Such a notice must be set aside, with any fresh action undertaken by a different officer.
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