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...
Principles of natural justice violated due to non-issuance of notice regarding discrepancies as mandated by Rule 101(4) of Central Goods and Services Tax Rules, 2017. Discrepancies existed between audit report and demands raised. Petitioner asserted providing all requested documents, while respondents issued reminders for document submission. Petitioner sought direction for adjudicating authority to consider responses to show cause notices without influence from audit memo or report observations. Court directed adjudicating authority to independently examine petitioner's reply to impugned show cause notice and take decision regarding proposed demand, without implicitly relying on audit memo or report observations. Petition disposed of.
Principles of natural justice violated due to non-issuance of notice regarding discrepancies as mandated by Rule 101(4) of Central Goods and Services Tax Rules, 2017. Discrepancies existed between audit report and demands raised. Petitioner asserted providing all requested documents, while respondents issued reminders for document submission. Petitioner sought direction for adjudicating authority to consider responses to show cause notices without influence from audit memo or report observations. Court directed adjudicating authority to independently examine petitioner's reply to impugned show cause notice and take decision regarding proposed demand, without implicitly relying on audit memo or report observations. Petition disposed of.
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