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 invalidated a GST assessment order in Form GST DRC-07 due to two fatal defects: absence of the assessing officer's signature and missing Document Identification Number (DIN). Following precedents established in A.V. Bhanoji Row and M/s. SRK Enterprises, the Court affirmed that an officer's signature cannot be dispensed with, and Sections 160 and 169 of CGST Act, 2017 cannot rectify such deficiency. Regarding the DIN requirement, the Court relied on the Supreme Court's ruling in Pradeep Goyal, which held that orders without DIN numbers are non-est and invalid, consistent with CBIC circulars. Consequently, the impugned assessment order was set aside and the petition disposed of.
The HC invalidated a GST assessment order in Form GST DRC-07 due to two fatal defects: absence of the assessing officer's signature and missing Document Identification Number (DIN). Following precedents established in A.V. Bhanoji Row and M/s. SRK Enterprises, the Court affirmed that an officer's signature cannot be dispensed with, and Sections 160 and 169 of CGST Act, 2017 cannot rectify such deficiency. Regarding the DIN requirement, the Court relied on the Supreme Court's ruling in Pradeep Goyal, which held that orders without DIN numbers are non-est and invalid, consistent with CBIC circulars. Consequently, the impugned assessment order was set aside and the petition disposed of.
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