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 quashed the order invoking Rule 86A for blocking the Electronic Credit Ledger (ECL) of the petitioner under the CGST/SGST Rules, 2017. The impugned order lacked independent or cogent reasons and relied on reports of enforcement authorities, which is impermissible. Crucially, no pre-decisional hearing was granted, violating principles of natural justice. The order erroneously described the supplier as non-existent or not conducting business, despite the supplier obtaining registration and the transaction occurring before cancellation of registration. The court held that the order failed to provide valid reasons for blocking the ECL, thereby warranting its quashing.
The High Court quashed the order invoking Rule 86A for blocking the Electronic Credit Ledger (ECL) of the petitioner under the CGST/SGST Rules, 2017. The impugned order lacked independent or cogent reasons and relied on reports of enforcement authorities, which is impermissible. Crucially, no pre-decisional hearing was granted, violating principles of natural justice. The order erroneously described the supplier as non-existent or not conducting business, despite the supplier obtaining registration and the transaction occurring before cancellation of registration. The court held that the order failed to provide valid reasons for blocking the ECL, thereby warranting its quashing.
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