Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
The HC disposed of the petition, directing the Competent Authority to consider separately for each year whether invocation of Section 74 of CGST/SGST Acts was warranted, particularly for 2018-19 through 2021-22 where petitioner claimed no justification existed. The Authority must credit any taxes already paid when finalizing proceedings. The Court explicitly mandated that petitioner be afforded an opportunity for personal hearing before the Adjudicating Authority renders its decision. The consolidated show cause notice covering 2017-18 through 2021-22 cannot stand in its current form and requires individualized assessment of each tax year's circumstances.
The HC disposed of the petition, directing the Competent Authority to consider separately for each year whether invocation of Section 74 of CGST/SGST Acts was warranted, particularly for 2018-19 through 2021-22 where petitioner claimed no justification existed. The Authority must credit any taxes already paid when finalizing proceedings. The Court explicitly mandated that petitioner be afforded an opportunity for personal hearing before the Adjudicating Authority renders its decision. The consolidated show cause notice covering 2017-18 through 2021-22 cannot stand in its current form and requires individualized assessment of each tax year's circumstances.
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