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...
HC quashed the impugned order rejecting petitioner's rectification application due to procedural error. The revenue authority incorrectly stated petitioner failed to reply to show cause notice, despite petitioner's timely response dated 22.01.2025 being duly acknowledged in Form GST DRC 06. Court found petitioner established grounds for judicial interference as the order contained factual inaccuracy regarding non-response. Matter remitted to respondent authority with directions to pass fresh order on merits within three months, ensuring petitioner's reply is considered and hearing opportunity provided. Petition allowed by way of remand, emphasizing adherence to principles of natural justice in administrative proceedings.
HC quashed the impugned order rejecting petitioner's rectification application due to procedural error. The revenue authority incorrectly stated petitioner failed to reply to show cause notice, despite petitioner's timely response dated 22.01.2025 being duly acknowledged in Form GST DRC 06. Court found petitioner established grounds for judicial interference as the order contained factual inaccuracy regarding non-response. Matter remitted to respondent authority with directions to pass fresh order on merits within three months, ensuring petitioner's reply is considered and hearing opportunity provided. Petition allowed by way of remand, emphasizing adherence to principles of natural justice in administrative proceedings.
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