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 dismissed petitioner's application under Section 161 of Goods and Services Act, 2017, holding that principles of natural justice are not mandatory when no actual rectification is performed and the applicant suffers no adverse impact. The court determined that the rectification provision requires adherence to natural justice only when specific conditions are met: (i) rectification is being carried out and (ii) such rectification potentially adversely affects the assessee. In this instance, the application was deemed vague and without substantive grounds, thus justifying rejection without a personal hearing.
HC dismissed petitioner's application under Section 161 of Goods and Services Act, 2017, holding that principles of natural justice are not mandatory when no actual rectification is performed and the applicant suffers no adverse impact. The court determined that the rectification provision requires adherence to natural justice only when specific conditions are met: (i) rectification is being carried out and (ii) such rectification potentially adversely affects the assessee. In this instance, the application was deemed vague and without substantive grounds, thus justifying rejection without a personal hearing.
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