Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Formal initiation under the tax demand regime requires a distinct Show Cause Notice and a Statement; a summary in FORM GST DRC-01 is supplementary and cannot substitute for the Section 73 Show Cause Notice, so attachment of a tax-determination statement to DRC-01 does not validly initiate proceedings. Documents constituting the SCN, Statement or final Order must be authenticated by the Proper Officer with electronic/digital e-signature under applicable rules; unauthenticated attachments lack legal efficacy. Where an adverse decision is contemplated, a personal hearing must be afforded as a statutory safeguard; failure to provide the mandated hearing breaches natural justice. The impugned order was set aside and fresh proceedings are permitted, with a specified exclusion for limitation.
Formal initiation under the tax demand regime requires a distinct Show Cause Notice and a Statement; a summary in FORM GST DRC-01 is supplementary and cannot substitute for the Section 73 Show Cause Notice, so attachment of a tax-determination statement to DRC-01 does not validly initiate proceedings. Documents constituting the SCN, Statement or final Order must be authenticated by the Proper Officer with electronic/digital e-signature under applicable rules; unauthenticated attachments lack legal efficacy. Where an adverse decision is contemplated, a personal hearing must be afforded as a statutory safeguard; failure to provide the mandated hearing breaches natural justice. The impugned order was set aside and fresh proceedings are permitted, with a specified exclusion for limitation.
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