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 set aside the assessment order due to procedural deficiencies in notice service. Despite portal upload, the court found insufficient efforts to ensure effective communication with the petitioner. The HC emphasized that merely uploading notices on the GST portal does not constitute proper service, especially when alternative notification methods under Section 169 were available. The court highlighted the need for officers to apply due diligence in serving notices to prevent ex parte orders that could lead to unnecessary litigation. The matter was remanded for fresh consideration, with the petitioner willing to pay 25% of the disputed tax, thus ensuring principles of natural justice were upheld.
HC set aside the assessment order due to procedural deficiencies in notice service. Despite portal upload, the court found insufficient efforts to ensure effective communication with the petitioner. The HC emphasized that merely uploading notices on the GST portal does not constitute proper service, especially when alternative notification methods under Section 169 were available. The court highlighted the need for officers to apply due diligence in serving notices to prevent ex parte orders that could lead to unnecessary litigation. The matter was remanded for fresh consideration, with the petitioner willing to pay 25% of the disputed tax, thus ensuring principles of natural justice were upheld.
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