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...
HC set aside GST assessment proceedings due to absence of Document Identification Number (DIN). Following SC precedent in Pradeep Goyal case and CBIC circular No. 128/47/2019-GST, the court determined that orders without DIN are non-est and invalid. The ruling aligns with previous HC Division Bench decisions in Cluster Enterprises and Sai Manikanta cases which established that non-mention of DIN invalidates proceedings. Court granted liberty to revenue authorities to conduct fresh assessment after proper notice to assessee and assignment of DIN number. The Form GST DRC-07 dated 26.06.2024 was consequently invalidated, emphasizing procedural compliance requirement in GST administration.
HC set aside GST assessment proceedings due to absence of Document Identification Number (DIN). Following SC precedent in Pradeep Goyal case and CBIC circular No. 128/47/2019-GST, the court determined that orders without DIN are non-est and invalid. The ruling aligns with previous HC Division Bench decisions in Cluster Enterprises and Sai Manikanta cases which established that non-mention of DIN invalidates proceedings. Court granted liberty to revenue authorities to conduct fresh assessment after proper notice to assessee and assignment of DIN number. The Form GST DRC-07 dated 26.06.2024 was consequently invalidated, emphasizing procedural compliance requirement in GST administration.
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