Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The HC held that the impugned adjudication orders dated 31.12.2023 and 23.09.2025 are unsustainable for having been passed without affording personal hearing, thereby violating principles of natural justice under Section 73 of the GST Act. Observing that personal hearing must ordinarily be offered before any adverse adjudicatory order and that waiver or failure to avail such hearing are distinct exceptions, the Court quashed the impugned orders and allowed the petition. The HC rejected the contention based on time-bar considerations insofar as procedural denial of hearing rendered the orders invalid, and directed appropriate further proceedings consistent with the requirement of personal hearing.
The HC held that the impugned adjudication orders dated 31.12.2023 and 23.09.2025 are unsustainable for having been passed without affording personal hearing, thereby violating principles of natural justice under Section 73 of the GST Act. Observing that personal hearing must ordinarily be offered before any adverse adjudicatory order and that waiver or failure to avail such hearing are distinct exceptions, the Court quashed the impugned orders and allowed the petition. The HC rejected the contention based on time-bar considerations insofar as procedural denial of hearing rendered the orders invalid, and directed appropriate further proceedings consistent with the requirement of personal hearing.
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