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...
The petitioner challenged the issuance of multiple audit memos determining tax liability beyond the stipulated period u/s 65(4) of the CGST/DGST Act. While the multiple audit memos indicating findings and demanding tax payment were irregular u/s 65(6), the impugned show cause notice (SCN) premised on the audit report findings is within the statutory framework. Any irregularities in issuing audit memos do not impinge the validity of the SCN. Therefore, the petition to quash the SCN at the threshold stage cannot be accepted, and the petition is disposed of.
The petitioner challenged the issuance of multiple audit memos determining tax liability beyond the stipulated period u/s 65(4) of the CGST/DGST Act. While the multiple audit memos indicating findings and demanding tax payment were irregular u/s 65(6), the impugned show cause notice (SCN) premised on the audit report findings is within the statutory framework. Any irregularities in issuing audit memos do not impinge the validity of the SCN. Therefore, the petition to quash the SCN at the threshold stage cannot be accepted, and the petition is disposed of.
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