Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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HC allowed the writ petition, quashing the subsequent order (Ext.P8) and rejection order (Ext.P14), recognizing that the initial order (Ext.P7) had already conclusively adjudicated the assessment discrepancies for 2017-2018. The court held that under Section 161 of the GST Act, rectification can be initiated suo motu when an error is apparent on record, particularly in cases involving mutually conflicting departmental orders. The petitioner's timely email communication within the statutory period was deemed significant in establishing the basis for rectification, despite the technical non-compliance with portal submission requirements.
HC allowed the writ petition, quashing the subsequent order (Ext.P8) and rejection order (Ext.P14), recognizing that the initial order (Ext.P7) had already conclusively adjudicated the assessment discrepancies for 2017-2018. The court held that under Section 161 of the GST Act, rectification can be initiated suo motu when an error is apparent on record, particularly in cases involving mutually conflicting departmental orders. The petitioner's timely email communication within the statutory period was deemed significant in establishing the basis for rectification, despite the technical non-compliance with portal submission requirements.
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