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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
