Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Uploading a show cause notice on the GST portal is a recognised mode of service, but where the taxpayer was unaware and the original was not furnished and no personal hearing was afforded, confirmation of proposals is unsustainable; the HC set aside the assessment and remitted the matter for fresh consideration, directing opportunity to file reply and a personal hearing. Officers are required to explore alternative prescribed modes of service under Section 169(1) (preferably RPAD) if portal service elicits no response. Attachment of the petitioner's bank account is ordered released and de frozen on production of this order.
Uploading a show cause notice on the GST portal is a recognised mode of service, but where the taxpayer was unaware and the original was not furnished and no personal hearing was afforded, confirmation of proposals is unsustainable; the HC set aside the assessment and remitted the matter for fresh consideration, directing opportunity to file reply and a personal hearing. Officers are required to explore alternative prescribed modes of service under Section 169(1) (preferably RPAD) if portal service elicits no response. Attachment of the petitioner's bank account is ordered released and de frozen on production of this order.
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