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...
Validity of summary of the order/demand notice in DRC-07 - allegation of wrongful availment of ITC without receipt of goods - It is evident that without proper opportunity of furnishing reply to the show-cause notice and without supplying the relied upon documents referred to in the inspection report, the petitioners have been prejudiced in defending themselves. The petitioners may have also lost the opportunity to cross-examine such persons as are relied upon by the tax authorities to support the impugned proceedings. Since the impugned proceedings are clearly in violation of principles of natural justice and the procedure prescribed under the JGST Act, the petitioners are justified in approaching this Court in writ jurisdiction. - HC
Validity of summary of the order/demand notice in DRC-07 - allegation of wrongful availment of ITC without receipt of goods - It is evident that without proper opportunity of furnishing reply to the show-cause notice and without supplying the relied upon documents referred to in the inspection report, the petitioners have been prejudiced in defending themselves. The petitioners may have also lost the opportunity to cross-examine such persons as are relied upon by the tax authorities to support the impugned proceedings. Since the impugned proceedings are clearly in violation of principles of natural justice and the procedure prescribed under the JGST Act, the petitioners are justified in approaching this Court in writ jurisdiction. - HC
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