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...
The Madhya Pradesh High Court directed the Respondent to release the original documents seized from the Petitioner's premises within 30 days of issuing the show cause notice, as per u/s 67(3) of the CGST Act and u/r 27 of the Central Excise Rules 2017. The Petitioner is entitled to both certified copies of relied documents and original copies of non-relied documents for a fair defense. The court emphasized the Petitioner's right to cross-examine witnesses relied upon in the show cause notices to ensure a fair hearing and adherence to principles of natural justice. The Respondents were ordered to provide all original seized documents to the Petitioner for preparing a reply, thereby allowing the petition.
The Madhya Pradesh High Court directed the Respondent to release the original documents seized from the Petitioner's premises within 30 days of issuing the show cause notice, as per u/s 67(3) of the CGST Act and u/r 27 of the Central Excise Rules 2017. The Petitioner is entitled to both certified copies of relied documents and original copies of non-relied documents for a fair defense. The court emphasized the Petitioner's right to cross-examine witnesses relied upon in the show cause notices to ensure a fair hearing and adherence to principles of natural justice. The Respondents were ordered to provide all original seized documents to the Petitioner for preparing a reply, thereby allowing the petition.
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