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 quashed the impugned order dated 14.08.2025, issued under section 73 for the tax period April 2020-March 2021, holding it arbitrary and in manifest violation of the principles of natural justice. The court observed the order followed a SCN in GST DRC-01 but lacked reasons and denied fair hearing. The matter is remitted to the respondent for de novo adjudication on merits, with a direction to afford the petitioner an opportunity of hearing before passing any fresh order. The respondent shall complete the reassessment and pass a reasoned order within six weeks of receipt of this judgment. The petition is disposed of by remand.
The HC quashed the impugned order dated 14.08.2025, issued under section 73 for the tax period April 2020-March 2021, holding it arbitrary and in manifest violation of the principles of natural justice. The court observed the order followed a SCN in GST DRC-01 but lacked reasons and denied fair hearing. The matter is remitted to the respondent for de novo adjudication on merits, with a direction to afford the petitioner an opportunity of hearing before passing any fresh order. The respondent shall complete the reassessment and pass a reasoned order within six weeks of receipt of this judgment. The petition is disposed of by remand.
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