Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Validity of demand with penalty u/s 73 of CGST Act - Petitioner argued that their detailed replies were not adequately considered, and they were not given an opportunity to clarify or provide further documents. The court found merit in these contentions, criticizing the proper officer for dismissing the petitioner's reply without proper assessment and for not providing opportunities for clarification. Consequently, the High court set aside the impugned order and directed the matter to be remitted for re-adjudication, emphasizing the importance of following principles of natural justice and affording parties due process.
Validity of demand with penalty u/s 73 of CGST Act - Petitioner argued that their detailed replies were not adequately considered, and they were not given an opportunity to clarify or provide further documents. The court found merit in these contentions, criticizing the proper officer for dismissing the petitioner's reply without proper assessment and for not providing opportunities for clarification. Consequently, the High court set aside the impugned order and directed the matter to be remitted for re-adjudication, emphasizing the importance of following principles of natural justice and affording parties due process.
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