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 dismissed petitioner's challenge to order under Section 73 of WBGST/CGST Act, 2017. Petitioner contended proper officer predetermined outcome by serving Form GST DRC-01A notice before show cause notice, violating natural justice. Court found no irregularity as petitioner received adequate opportunity to respond to show cause before personal hearing was scheduled. Despite petitioner's claim of unawareness due to accountant change, Court noted petitioner continued portal operations and filing returns throughout proceedings. Section 75(4) permits hearing opportunity when adverse decision is contemplated. Petitioner failed to appear for scheduled hearing, thus cannot question the process. No predetermination or natural justice violation established. Petition disposed of without interference to impugned order.
HC dismissed petitioner's challenge to order under Section 73 of WBGST/CGST Act, 2017. Petitioner contended proper officer predetermined outcome by serving Form GST DRC-01A notice before show cause notice, violating natural justice. Court found no irregularity as petitioner received adequate opportunity to respond to show cause before personal hearing was scheduled. Despite petitioner's claim of unawareness due to accountant change, Court noted petitioner continued portal operations and filing returns throughout proceedings. Section 75(4) permits hearing opportunity when adverse decision is contemplated. Petitioner failed to appear for scheduled hearing, thus cannot question the process. No predetermination or natural justice violation established. Petition disposed of without interference to impugned order.
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