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 dismissed the writ petition challenging the validity of show cause notice issued under CGST Act Section 122(1A). The court held that mere issuance of SCN does not infringe any rights and writ petition is premature without final adjudication order. Following established SC precedent, HC refused to interfere at preliminary stage, emphasizing that petitioner retains liberty to contest validity of proceedings before adjudicating authority. Court noted petitioner may file appropriate application for cross-examination of witnesses before competent authority in accordance with law. The petition was disposed of with directions that all grounds including natural justice violations may be raised during adjudication proceedings.
HC dismissed the writ petition challenging the validity of show cause notice issued under CGST Act Section 122(1A). The court held that mere issuance of SCN does not infringe any rights and writ petition is premature without final adjudication order. Following established SC precedent, HC refused to interfere at preliminary stage, emphasizing that petitioner retains liberty to contest validity of proceedings before adjudicating authority. Court noted petitioner may file appropriate application for cross-examination of witnesses before competent authority in accordance with law. The petition was disposed of with directions that all grounds including natural justice violations may be raised during adjudication proceedings.
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