Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The HC set aside the impugned orders dated 12.03.2025 for violating principles of natural justice and contravening Section 75(4) of the TNGST Act. The respondent authority rejected the petitioner's reply as unacceptable and confirmed defects without providing mandatory opportunity of hearing required under the statutory provision when adverse decisions are contemplated against taxpayers. The court found the orders procedurally flawed as they failed to comply with natural justice requirements and statutory mandates. The petition was allowed by way of remand, directing the respondent to undertake fresh consideration of the matter while ensuring compliance with due process requirements and providing adequate hearing opportunity to the petitioner before making any adverse determination.
The HC set aside the impugned orders dated 12.03.2025 for violating principles of natural justice and contravening Section 75(4) of the TNGST Act. The respondent authority rejected the petitioner's reply as unacceptable and confirmed defects without providing mandatory opportunity of hearing required under the statutory provision when adverse decisions are contemplated against taxpayers. The court found the orders procedurally flawed as they failed to comply with natural justice requirements and statutory mandates. The petition was allowed by way of remand, directing the respondent to undertake fresh consideration of the matter while ensuring compliance with due process requirements and providing adequate hearing opportunity to the petitioner before making any adverse determination.
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