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 and set aside the impugned order-in-original regarding recovery of alleged excess ITC, finding it was passed in violation of principles of natural justice and Section 75(4) of the CGST Act. The respondent authority failed to grant the petitioners a personal hearing before passing an adverse order. The matter was remanded for fresh de novo proceedings, directing the authority to provide the petitioners an opportunity to reconcile Form GSTR 2A with Form GSTR 3B for the period under consideration. The court ordered completion of this exercise within 12 weeks from receipt of the order.
The HC quashed and set aside the impugned order-in-original regarding recovery of alleged excess ITC, finding it was passed in violation of principles of natural justice and Section 75(4) of the CGST Act. The respondent authority failed to grant the petitioners a personal hearing before passing an adverse order. The matter was remanded for fresh de novo proceedings, directing the authority to provide the petitioners an opportunity to reconcile Form GSTR 2A with Form GSTR 3B for the period under consideration. The court ordered completion of this exercise within 12 weeks from receipt of the order.
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