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 set aside the impugned suo motu order passed under Section 108 of the Chhattisgarh GST Act, 2017, on grounds of violation of natural justice and lack of jurisdiction at the time of issuance. The Court held that the revisional authority was not validly empowered to pass the order on 01.06.2019, as the relevant notification authorizing such authority was issued only on 07.08.2020. Furthermore, the order failed to provide any cogent reasons or record the requisite satisfaction for exercising revisionary powers, rendering it unsustainable. Consequently, the HC directed the concerned authority to discontinue the revision proceedings forthwith and allowed the petition.
The HC set aside the impugned suo motu order passed under Section 108 of the Chhattisgarh GST Act, 2017, on grounds of violation of natural justice and lack of jurisdiction at the time of issuance. The Court held that the revisional authority was not validly empowered to pass the order on 01.06.2019, as the relevant notification authorizing such authority was issued only on 07.08.2020. Furthermore, the order failed to provide any cogent reasons or record the requisite satisfaction for exercising revisionary powers, rendering it unsustainable. Consequently, the HC directed the concerned authority to discontinue the revision proceedings forthwith and allowed the petition.
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