Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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HC held that the audit under Section 65 CGST Act was not time-barred: the audit commencement date was fixed as the day after the Petitioner's final submission, mandating conclusion within three months, and the audit report dated 11 Feb 2025 and communicated 13 Feb 2025 was within limitation. Conversely, the show-cause notice issued on 27 Nov 2024 was quashed for breach of natural justice because it was issued before the expiry of the period granted to the Petitioner to reply to the pre-SCN; the SCN is set aside and the matter is remitted to the pre-SCN stage. The Petitioner may file its response to the pre-SCN dated 25 Nov 2024 on or before 10 Nov 2025. Case disposed.
HC held that the audit under Section 65 CGST Act was not time-barred: the audit commencement date was fixed as the day after the Petitioner's final submission, mandating conclusion within three months, and the audit report dated 11 Feb 2025 and communicated 13 Feb 2025 was within limitation. Conversely, the show-cause notice issued on 27 Nov 2024 was quashed for breach of natural justice because it was issued before the expiry of the period granted to the Petitioner to reply to the pre-SCN; the SCN is set aside and the matter is remitted to the pre-SCN stage. The Petitioner may file its response to the pre-SCN dated 25 Nov 2024 on or before 10 Nov 2025. Case disposed.
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