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 adjudicated a tax dispute involving procedural irregularities in service of show cause notice (SCN). The court found that a consolidated SCN was issued across multiple financial years under Section 74 of the Central Goods and Service Tax Act, 2017, addressing short payment and input tax credit issues. Despite no prior hearing notice to the Petitioner, the court held that the Petitioner retains the right to submit arguments and challenge the impugned order. The petition was disposed of, allowing the Petitioner procedural opportunities to present their case in subsequent proceedings.
HC adjudicated a tax dispute involving procedural irregularities in service of show cause notice (SCN). The court found that a consolidated SCN was issued across multiple financial years under Section 74 of the Central Goods and Service Tax Act, 2017, addressing short payment and input tax credit issues. Despite no prior hearing notice to the Petitioner, the court held that the Petitioner retains the right to submit arguments and challenge the impugned order. The petition was disposed of, allowing the Petitioner procedural opportunities to present their case in subsequent proceedings.
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