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 held that the non-service of the Show Cause Notice (SCN) and denial of personal hearing constituted a violation of natural justice principles. Consequently, the impugned order-in-original demanding recovery for wrongful availment of Input Tax Credit against the Petitioners was set aside. The Court directed the Adjudicating Authority to adjudicate the SCN afresh after considering the Petitioners' reply and submissions. The petition was disposed of accordingly.
The HC held that the non-service of the Show Cause Notice (SCN) and denial of personal hearing constituted a violation of natural justice principles. Consequently, the impugned order-in-original demanding recovery for wrongful availment of Input Tax Credit against the Petitioners was set aside. The Court directed the Adjudicating Authority to adjudicate the SCN afresh after considering the Petitioners' reply and submissions. The petition was disposed of accordingly.
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