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...
Violation of principles of natural justice occurred as the impugned SCN was uploaded under 'View Additional Notices & Orders' category, claimed to be inaccessible by petitioner. Court held that issue was covered by earlier decisions rejecting contention that uploading notices under 'Additional Notices' constituted sufficient service u/s 169 of CGST Act, 2017. GST Authorities redesigned portal to ensure 'View Notices' and 'View Additional Notices' tabs are adjacent. Impugned SCN was issued before portal redesign. Petition allowed, impugned order set aside, matter remanded for fresh adjudication of SCN.
Violation of principles of natural justice occurred as the impugned SCN was uploaded under 'View Additional Notices & Orders' category, claimed to be inaccessible by petitioner. Court held that issue was covered by earlier decisions rejecting contention that uploading notices under 'Additional Notices' constituted sufficient service u/s 169 of CGST Act, 2017. GST Authorities redesigned portal to ensure 'View Notices' and 'View Additional Notices' tabs are adjacent. Impugned SCN was issued before portal redesign. Petition allowed, impugned order set aside, matter remanded for fresh adjudication of SCN.
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