Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
HC set aside the Rectification Order dated 28 June 2024 and disposed of the writ petition. The Court found the impugned rectification order to be mechanical, lacking reasons and failing to apply the principle of natural justice by not affording a personal hearing when the order adversely affected the assessee. Although the petitioner filed a reply and attributed delay to a dispute with a GST consultant, the delay in challenging the December 2023 order was inadequately explained and did not justify condonation; the petitioner had the opportunity to file submissions. Nevertheless, because the rectification was issued without reasoned assessment or hearing, the HC annulled that rectification.
HC set aside the Rectification Order dated 28 June 2024 and disposed of the writ petition. The Court found the impugned rectification order to be mechanical, lacking reasons and failing to apply the principle of natural justice by not affording a personal hearing when the order adversely affected the assessee. Although the petitioner filed a reply and attributed delay to a dispute with a GST consultant, the delay in challenging the December 2023 order was inadequately explained and did not justify condonation; the petitioner had the opportunity to file submissions. Nevertheless, because the rectification was issued without reasoned assessment or hearing, the HC annulled that rectification.
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