Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
The HC quashed an ex-parte adjudication order requiring the petitioner-company to pay Rs. 2,20,75,208/- in tax, interest, and penalty under Section 73 of the KGST Act. Despite the petitioner's failure to respond to both the intimation dated 28.11.2023 and the show cause notice dated 08.12.2023, or to participate in the proceedings, the Court adopted a justice-oriented approach. The matter was remanded to respondent No. 3, providing the petitioner one more opportunity to submit a reply to the show cause notice and contest the proceedings. The Court made no determination on the merits of the case, directing further proceedings in accordance with law.
The HC quashed an ex-parte adjudication order requiring the petitioner-company to pay Rs. 2,20,75,208/- in tax, interest, and penalty under Section 73 of the KGST Act. Despite the petitioner's failure to respond to both the intimation dated 28.11.2023 and the show cause notice dated 08.12.2023, or to participate in the proceedings, the Court adopted a justice-oriented approach. The matter was remanded to respondent No. 3, providing the petitioner one more opportunity to submit a reply to the show cause notice and contest the proceedings. The Court made no determination on the merits of the case, directing further proceedings in accordance with law.
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