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...
Parallel GST adjudication on the same subject matter cannot continue once proceedings have been initiated by one authority, and Central and State authorities must coordinate to ermine which authority will proceed so the assessee is not exposed to duplicate adjudication for the same period and contravention. The Court also permitted the taxpayer to file fresh responses to the notices and directed the competent authority to consider the replies and supporting documents, hear the taxpayer, and pass a speaking and reasoned order in accordance with law. The constitutional challenge was not pressed, and the merits of the input tax credit claim were left open.
Parallel GST adjudication on the same subject matter cannot continue once proceedings have been initiated by one authority, and Central and State authorities must coordinate to ermine which authority will proceed so the assessee is not exposed to duplicate adjudication for the same period and contravention. The Court also permitted the taxpayer to file fresh responses to the notices and directed the competent authority to consider the replies and supporting documents, hear the taxpayer, and pass a speaking and reasoned order in accordance with law. The constitutional challenge was not pressed, and the merits of the input tax credit claim were left open.
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