Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
HC set aside ex-parte order against petitioner due to violation of natural justice principles. The court found that no opportunity for personal hearing was provided before issuing demand with interest and penalty. The impugned order was quashed, directing the adjudicating authority to consider petitioner's reply to show cause notice and submissions during personal hearing, and pass a fresh order. The challenge to underlying notifications was also held subject to ongoing Supreme Court proceedings in a related matter, ensuring procedural fairness and preserving petitioner's right to be heard.
HC set aside ex-parte order against petitioner due to violation of natural justice principles. The court found that no opportunity for personal hearing was provided before issuing demand with interest and penalty. The impugned order was quashed, directing the adjudicating authority to consider petitioner's reply to show cause notice and submissions during personal hearing, and pass a fresh order. The challenge to underlying notifications was also held subject to ongoing Supreme Court proceedings in a related matter, ensuring procedural fairness and preserving petitioner's right to be heard.
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