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 set aside orders passed under section 73 of the Act that were merely uploaded to the GST Portal without proper service to the petitioner. The court found these ex parte orders violated principles of natural justice as the petitioner had no opportunity to view the notices on the portal, file replies, or appear for personal hearings. While noting that no deposit conditions could be imposed for orders violating natural justice, the court acknowledged the petitioner's voluntary offer to deposit 25% of the disputed tax. The matters were remanded to the respondent for fresh consideration subject to fulfillment of conditions imposed.
The HC set aside orders passed under section 73 of the Act that were merely uploaded to the GST Portal without proper service to the petitioner. The court found these ex parte orders violated principles of natural justice as the petitioner had no opportunity to view the notices on the portal, file replies, or appear for personal hearings. While noting that no deposit conditions could be imposed for orders violating natural justice, the court acknowledged the petitioner's voluntary offer to deposit 25% of the disputed tax. The matters were remanded to the respondent for fresh consideration subject to fulfillment of conditions imposed.
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