Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
HC set aside assessment order dated 08.08.2024 for violating principles of natural justice where petitioner received no personal hearing opportunity. Despite show cause notice being uploaded on GST Portal, petitioner claimed unawareness and non-receipt of original notice. Court held that while portal service is valid, revenue officers must explore alternative service modes under Section 169 GST Act when taxpayers remain unresponsive, preferably through RPAD, to ensure effective service rather than mere procedural compliance. Matter remanded to respondent for fresh consideration conditional upon petitioner depositing 25% of disputed tax amount within four weeks. Petition allowed by way of remand.
HC set aside assessment order dated 08.08.2024 for violating principles of natural justice where petitioner received no personal hearing opportunity. Despite show cause notice being uploaded on GST Portal, petitioner claimed unawareness and non-receipt of original notice. Court held that while portal service is valid, revenue officers must explore alternative service modes under Section 169 GST Act when taxpayers remain unresponsive, preferably through RPAD, to ensure effective service rather than mere procedural compliance. Matter remanded to respondent for fresh consideration conditional upon petitioner depositing 25% of disputed tax amount within four weeks. Petition allowed by way of remand.
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