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...
The HC quashed orders blocking petitioner's Electronic Credit Ledger and provisionally attaching bank account under Rule 86A of Central Goods and Services Tax Rules, 2017. The court held that respondents failed to provide pre-decisional hearing, violating principles of natural justice, and lacked independent cogent reasons to believe as required under Rule 86A. The impugned orders relied on borrowed satisfaction from enforcement authority reports, which is impermissible in law. The court found the orders illegal and arbitrary for non-compliance with mandatory procedural and substantive requirements. Respondents were directed to immediately unblock petitioner's Electronic Credit Ledger upon receipt of the order to enable filing of returns. Petition allowed.
The HC quashed orders blocking petitioner's Electronic Credit Ledger and provisionally attaching bank account under Rule 86A of Central Goods and Services Tax Rules, 2017. The court held that respondents failed to provide pre-decisional hearing, violating principles of natural justice, and lacked independent cogent reasons to believe as required under Rule 86A. The impugned orders relied on borrowed satisfaction from enforcement authority reports, which is impermissible in law. The court found the orders illegal and arbitrary for non-compliance with mandatory procedural and substantive requirements. Respondents were directed to immediately unblock petitioner's Electronic Credit Ledger upon receipt of the order to enable filing of returns. Petition allowed.
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