Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Allegations of bogus or paper transactions in the supply chain can support cancellation of GST registration even while return scrutiny is pending, because the two proceedings may run separately and the pendency of scrutiny creates no legal bar. Where the cancellation notice turns on disputed facts, writ jurisdiction is not the proper forum for fact-finding, and the controversy must be tested on evidence before the statutory authority. The High Court therefore declined interference under Article 226, found no adverse meaning could be attached merely to the reference to pending scrutiny, and left the assessee to pursue the statutory appeal on merits.
Allegations of bogus or paper transactions in the supply chain can support cancellation of GST registration even while return scrutiny is pending, because the two proceedings may run separately and the pendency of scrutiny creates no legal bar. Where the cancellation notice turns on disputed facts, writ jurisdiction is not the proper forum for fact-finding, and the controversy must be tested on evidence before the statutory authority. The High Court therefore declined interference under Article 226, found no adverse meaning could be attached merely to the reference to pending scrutiny, and left the assessee to pursue the statutory appeal on merits.
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