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 passed under Section 74 of the TNGST Act, 2017, finding procedural irregularities constituting double jeopardy. The court identified that Form GST DRC 05 was incorrectly issued instead of the proper GST DRC 07 format for adjudication orders. The impugned order dated 27.08.2024 was passed without petitioner's participation in proceedings initiated via DRC 01 dated 20.12.2023, creating procedural overlap. The HC remitted the matter to the first respondent with directions to pass fresh orders on merit in accordance with law within 30 days of receiving the judgment copy. The petition was disposed of with the quashing of the contested orders.
The HC quashed orders passed under Section 74 of the TNGST Act, 2017, finding procedural irregularities constituting double jeopardy. The court identified that Form GST DRC 05 was incorrectly issued instead of the proper GST DRC 07 format for adjudication orders. The impugned order dated 27.08.2024 was passed without petitioner's participation in proceedings initiated via DRC 01 dated 20.12.2023, creating procedural overlap. The HC remitted the matter to the first respondent with directions to pass fresh orders on merit in accordance with law within 30 days of receiving the judgment copy. The petition was disposed of with the quashing of the contested orders.
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