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 allowed the writ petition, holding that the impugned composite assessment order in Form GST DRC-07 dated 09.01.2025 and the corresponding summaries dated 17.01.2025 issued against the petitioner are set aside and the matters remanded to the 1st respondent for fresh adjudication after affording due opportunity of hearing. The Court clarified that electronically issued show-cause notices and summaries require digital authentication but, where an RFN indicates affixation of a digital signature, challenge on absence of physical/digital signature is negated. Further, issuing a common SCN or common order for multiple assessment periods is impermissible; separate SCNs, orders and summaries must be issued for each tax period.
The HC allowed the writ petition, holding that the impugned composite assessment order in Form GST DRC-07 dated 09.01.2025 and the corresponding summaries dated 17.01.2025 issued against the petitioner are set aside and the matters remanded to the 1st respondent for fresh adjudication after affording due opportunity of hearing. The Court clarified that electronically issued show-cause notices and summaries require digital authentication but, where an RFN indicates affixation of a digital signature, challenge on absence of physical/digital signature is negated. Further, issuing a common SCN or common order for multiple assessment periods is impermissible; separate SCNs, orders and summaries must be issued for each tax period.
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