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International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
HC ruled that blocking of Electronic Credit Ledger (ECL) under Rule 86A of CGST Rules, 2017 was procedurally invalid. The order was quashed due to absence of pre-decisional hearing, lack of independent reasons to believe, and reliance on borrowed satisfaction from enforcement authorities. The court directed immediate unblocking of petitioner's ECL, emphasizing principles of natural justice. The impugned order was deemed illegal and arbitrary, thus rendering the ECL blockage null and void. Respondents were mandated to restore the petitioner's ECL forthwith, enabling normal tax compliance proceedings.
HC ruled that blocking of Electronic Credit Ledger (ECL) under Rule 86A of CGST Rules, 2017 was procedurally invalid. The order was quashed due to absence of pre-decisional hearing, lack of independent reasons to believe, and reliance on borrowed satisfaction from enforcement authorities. The court directed immediate unblocking of petitioner's ECL, emphasizing principles of natural justice. The impugned order was deemed illegal and arbitrary, thus rendering the ECL blockage null and void. Respondents were mandated to restore the petitioner's ECL forthwith, enabling normal tax compliance proceedings.
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