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 ex parte assessment order dated 21 February 2025 passed under s.73 of the GST Act against the petitioner, finding failure of service of statutory notices (GST ASMT-10/ASMT-11) and denial of opportunity to be heard contrary to principles of natural justice. The writ petition was disposed directing the relevant authority to serve the outstanding documents upon the petitioner within seven days and afford an opportunity to file replies/explanations; further proceedings under s.73 are to proceed thereafter in accordance with law. The order compels fresh adjudication only after valid service and compliance with hearing requirements.
The HC set aside the ex parte assessment order dated 21 February 2025 passed under s.73 of the GST Act against the petitioner, finding failure of service of statutory notices (GST ASMT-10/ASMT-11) and denial of opportunity to be heard contrary to principles of natural justice. The writ petition was disposed directing the relevant authority to serve the outstanding documents upon the petitioner within seven days and afford an opportunity to file replies/explanations; further proceedings under s.73 are to proceed thereafter in accordance with law. The order compels fresh adjudication only after valid service and compliance with hearing requirements.
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