Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The HC disposed of the writ petition by setting aside the summary of show cause notice dated 08.05.2024 and summary of order dated 30.08.2024 for violating principles of natural justice. The respondent authorities issued summaries without proper SCN under Section 73(1) of CGST Act, 2017 and without passing orders under Section 73(9). Following the precedent established in Construction Catalysers Pvt. Ltd., the court found similar procedural violations where authorities incorrectly assumed that attaching tax determination to summary SCN constituted valid notice. The court granted liberty to respondent authorities to initiate de novo proceedings under Section 73 if deemed appropriate for the relevant financial year, ensuring proper procedural compliance while addressing the underlying tax issues.
The HC disposed of the writ petition by setting aside the summary of show cause notice dated 08.05.2024 and summary of order dated 30.08.2024 for violating principles of natural justice. The respondent authorities issued summaries without proper SCN under Section 73(1) of CGST Act, 2017 and without passing orders under Section 73(9). Following the precedent established in Construction Catalysers Pvt. Ltd., the court found similar procedural violations where authorities incorrectly assumed that attaching tax determination to summary SCN constituted valid notice. The court granted liberty to respondent authorities to initiate de novo proceedings under Section 73 if deemed appropriate for the relevant financial year, ensuring proper procedural compliance while addressing the underlying tax issues.
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