Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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Section 6(2)(b) bars parallel adjudicatory proceedings on the same subject matter, but summons and other investigative steps do not by themselves amount to initiation of such proceedings. Applying the Supreme Court's ruling in Armour Security, the HC noted possible overlap between Central and State GST action, but declined to decide the merits of that overlap on the material before it. It directed the assessee to comply with the summons and raise the objection before the concerned authority, while requiring the State and Central authorities to communicate and coordinate so that the assessee is not subjected to multiple adjudicatory processes on the same subject matter. The merits and validity of the summons and notice were left open.
Section 6(2)(b) bars parallel adjudicatory proceedings on the same subject matter, but summons and other investigative steps do not by themselves amount to initiation of such proceedings. Applying the Supreme Court's ruling in Armour Security, the HC noted possible overlap between Central and State GST action, but declined to decide the merits of that overlap on the material before it. It directed the assessee to comply with the summons and raise the objection before the concerned authority, while requiring the State and Central authorities to communicate and coordinate so that the assessee is not subjected to multiple adjudicatory processes on the same subject matter. The merits and validity of the summons and notice were left open.
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