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...
HC ruled on input tax credit rectification under Section 161 of Delhi GST Act, finding procedural irregularities in the administrative order. The court held that when rectification potentially adversely impacts the applicant's rights, principles of natural justice mandate providing personal hearing. Since the petitioner was not afforded an opportunity to be heard, the rectification order dated 28th February 2025 was set aside, thereby ensuring due process and fundamental fairness in administrative proceedings.
HC ruled on input tax credit rectification under Section 161 of Delhi GST Act, finding procedural irregularities in the administrative order. The court held that when rectification potentially adversely impacts the applicant's rights, principles of natural justice mandate providing personal hearing. Since the petitioner was not afforded an opportunity to be heard, the rectification order dated 28th February 2025 was set aside, thereby ensuring due process and fundamental fairness in administrative proceedings.
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