Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
HC, dealing with a challenge to extension of limitation for issuance of SCN and vires of N/N. 9/2023-Central Tax and N/N. 56/2023-Central Tax, noted that the issue of validity of the notifications is pending before SC in a related batch. In the present matter, the Petitioner, a stock broker, asserted that the SCN dated 30.05.2024 never came to its knowledge due to an internal lapse by its accountant, resulting in no reply being filed. HC held that, in these circumstances, neither the SCN nor the consequent demand can be sustained. The impugned order was set aside, and the matter remitted for fresh adjudication after personal hearing on a fixed date. Petition disposed.
HC, dealing with a challenge to extension of limitation for issuance of SCN and vires of N/N. 9/2023-Central Tax and N/N. 56/2023-Central Tax, noted that the issue of validity of the notifications is pending before SC in a related batch. In the present matter, the Petitioner, a stock broker, asserted that the SCN dated 30.05.2024 never came to its knowledge due to an internal lapse by its accountant, resulting in no reply being filed. HC held that, in these circumstances, neither the SCN nor the consequent demand can be sustained. The impugned order was set aside, and the matter remitted for fresh adjudication after personal hearing on a fixed date. Petition disposed.
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