Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
HC quashes impugned order and accompanying notice/endorsement blocking the petitioner's Electronic Credit Ledger, finding both to be cryptic, laconic and non-speaking, lacking recorded reasons to believe fraud or ineligibility for Input Tax Credit and thereby violative of natural justice. The court holds availability of an appellate remedy does not preclude exercise of its writ jurisdiction under Article 226 given the procedural infirmities. The respondents are directed to unblock the Electronic Credit Ledger immediately, subject to the petitioner maintaining a minimum balance equal to 10% of the tax demand reflected in the impugned order, and respondents are granted liberty to issue a fresh reasoned notice and proceed in accordance with law. Petition allowed.
HC quashes impugned order and accompanying notice/endorsement blocking the petitioner's Electronic Credit Ledger, finding both to be cryptic, laconic and non-speaking, lacking recorded reasons to believe fraud or ineligibility for Input Tax Credit and thereby violative of natural justice. The court holds availability of an appellate remedy does not preclude exercise of its writ jurisdiction under Article 226 given the procedural infirmities. The respondents are directed to unblock the Electronic Credit Ledger immediately, subject to the petitioner maintaining a minimum balance equal to 10% of the tax demand reflected in the impugned order, and respondents are granted liberty to issue a fresh reasoned notice and proceed in accordance with law. Petition allowed.
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