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...
The HC quashed the order blocking petitioner's Electronic Credit Ledger under Rule 86A of CGST/SGST Rules. The court found that the impugned order lacked independent reasoning, instead relying on enforcement authority reports which constituted "borrowed satisfaction." Additionally, no pre-decisional hearing was granted to the petitioner before blocking the ECL, violating principles of natural justice. The order merely stated the registered person was "found to be a bill trader and involved in issuance/availment in fake invoices" without providing substantive reasoning. The court determined these procedural and substantive defects rendered the blocking order legally untenable and allowed the petition.
The HC quashed the order blocking petitioner's Electronic Credit Ledger under Rule 86A of CGST/SGST Rules. The court found that the impugned order lacked independent reasoning, instead relying on enforcement authority reports which constituted "borrowed satisfaction." Additionally, no pre-decisional hearing was granted to the petitioner before blocking the ECL, violating principles of natural justice. The order merely stated the registered person was "found to be a bill trader and involved in issuance/availment in fake invoices" without providing substantive reasoning. The court determined these procedural and substantive defects rendered the blocking order legally untenable and allowed the petition.
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