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 found a violation of principles of natural justice as the notices were uploaded on the "view additional notices and orders" tab of the GST portal, and the petitioner was unaware of the proceedings. The impugned order pertained to discrepancies between the petitioner's GSTR-3B return, auto-populated GSTR-2A, and reconciliation of turnover as per the Income Tax return and GSTR-3B return. The tax proposal was confirmed due to the petitioner's failure to reply to the show cause notice. Considering these circumstances, the High Court set aside the impugned order dated 9-8-2023 on the condition that the petitioner remits 10% of the disputed tax demand within two weeks and submits a reply to the show cause notice within the same period. The petition was disposed of accordingly.
The High Court found a violation of principles of natural justice as the notices were uploaded on the "view additional notices and orders" tab of the GST portal, and the petitioner was unaware of the proceedings. The impugned order pertained to discrepancies between the petitioner's GSTR-3B return, auto-populated GSTR-2A, and reconciliation of turnover as per the Income Tax return and GSTR-3B return. The tax proposal was confirmed due to the petitioner's failure to reply to the show cause notice. Considering these circumstances, the High Court set aside the impugned order dated 9-8-2023 on the condition that the petitioner remits 10% of the disputed tax demand within two weeks and submits a reply to the show cause notice within the same period. The petition was disposed of accordingly.
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