Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
HC set aside refund rejection order under GST RFD-06 concerning export transactions with IGST payment. Petitioner, a manufacturer-exporter, made zero-rated supplies under Section 16 of IGST Act, 2017, through invoices dated April 17 and June 3, 2023, with corresponding shipping bills. Refund was withheld under Rule 96(4) due to data mismatch between shipping bills and GSTR-1. Court found violation of natural justice principles as petitioner wasn't given adequate opportunity to respond to show cause notice. Emphasizing benefit of doubt doctrine, HC invalidated refund rejection order dated September 25, 2024, directing fresh consideration of refund claim after providing proper hearing opportunity.
HC set aside refund rejection order under GST RFD-06 concerning export transactions with IGST payment. Petitioner, a manufacturer-exporter, made zero-rated supplies under Section 16 of IGST Act, 2017, through invoices dated April 17 and June 3, 2023, with corresponding shipping bills. Refund was withheld under Rule 96(4) due to data mismatch between shipping bills and GSTR-1. Court found violation of natural justice principles as petitioner wasn't given adequate opportunity to respond to show cause notice. Emphasizing benefit of doubt doctrine, HC invalidated refund rejection order dated September 25, 2024, directing fresh consideration of refund claim after providing proper hearing opportunity.
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