Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
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TP Adjustment - selection of MAM - CUP method or TNMM - it is not the case of the Petitioner that a hearing was not held. In fact, the Petitioners have averred that on 1st December, 2020, the final hearing in the matter was conducted by Respondent No. 2. The Petitioner had also filed its written submissions before Respondent No. 2 on the subject matter, raising the plea of consistency. Besides, detailed submissions on merit, along with the relevant materials have also been filed in support thereof. Thus, we cannot attribute any violation of breach of natural justice to the DRP on the ground of not affording an opportunity of hearing. - HC
TP Adjustment - selection of MAM - CUP method or TNMM - it is not the case of the Petitioner that a hearing was not held. In fact, the Petitioners have averred that on 1st December, 2020, the final hearing in the matter was conducted by Respondent No. 2. The Petitioner had also filed its written submissions before Respondent No. 2 on the subject matter, raising the plea of consistency. Besides, detailed submissions on merit, along with the relevant materials have also been filed in support thereof. Thus, we cannot attribute any violation of breach of natural justice to the DRP on the ground of not affording an opportunity of hearing. - HC
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