Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
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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