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 penalty orders and their common summary in Form GST DRC-07 (dated 06.06.2025) on grounds of procedural infirmity-absence of the assessing officer's digital signature and omission of a DIN-finding such defects render the orders invalid and breach principles of natural justice. The writ petition was disposed of, with the Court granting the Respondent liberty to initiate fresh assessment proceedings, subject to issuance of proper notice and execution of the resultant orders bearing an assigned signature and DIN. No costs were awarded.
The HC set aside the impugned penalty orders and their common summary in Form GST DRC-07 (dated 06.06.2025) on grounds of procedural infirmity-absence of the assessing officer's digital signature and omission of a DIN-finding such defects render the orders invalid and breach principles of natural justice. The writ petition was disposed of, with the Court granting the Respondent liberty to initiate fresh assessment proceedings, subject to issuance of proper notice and execution of the resultant orders bearing an assigned signature and DIN. No costs were awarded.
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