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...
The HC set aside the impugned assessment order dated 28.08.2024 for AY 2019-2020 and consequential proceedings, applying precedent from MR. SAHULHAMEED case which established that assessees are entitled to service of notice under the modes prescribed in clauses (a), (b), and (c) of Section 169(1) of CGST Act, 2017. The petitioner was directed to submit a reply to the show cause notice within two weeks, after which respondent must provide a hearing opportunity before passing orders on merits. Any bank attachment made was ordered to be released. The petition was allowed.
The HC set aside the impugned assessment order dated 28.08.2024 for AY 2019-2020 and consequential proceedings, applying precedent from MR. SAHULHAMEED case which established that assessees are entitled to service of notice under the modes prescribed in clauses (a), (b), and (c) of Section 169(1) of CGST Act, 2017. The petitioner was directed to submit a reply to the show cause notice within two weeks, after which respondent must provide a hearing opportunity before passing orders on merits. Any bank attachment made was ordered to be released. The petition was allowed.
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