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 High Court set aside the impugned orders and consequential GST DRC-13 notice for attachment of Bank Account issued by the tax authority for the assessment year 2017-2018. The issue pertained to a mismatch of tax liability between GSTR-3B and GSTR-2A filed by the petitioner. The Court held that the principles of natural justice were violated as the show cause notice was uploaded on the GST Portal, and the petitioner was unaware of its issuance. The impugned order was passed without affording an opportunity of personal hearing to the petitioner to establish its case. Consequently, the Court provided an opportunity to the petitioner to establish their case on merits and in accordance with law, subject to conditions imposed.
The High Court set aside the impugned orders and consequential GST DRC-13 notice for attachment of Bank Account issued by the tax authority for the assessment year 2017-2018. The issue pertained to a mismatch of tax liability between GSTR-3B and GSTR-2A filed by the petitioner. The Court held that the principles of natural justice were violated as the show cause notice was uploaded on the GST Portal, and the petitioner was unaware of its issuance. The impugned order was passed without affording an opportunity of personal hearing to the petitioner to establish its case. Consequently, the Court provided an opportunity to the petitioner to establish their case on merits and in accordance with law, subject to conditions imposed.
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