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...
Writ jurisdiction was not entertained to challenge GST proceedings after the statutory appeal period had expired, because the petitioner had replied to the show cause notice and been heard, so jurisdictional error and breach of natural justice were not established. The High Court held that Article 226 cannot be used to bypass a special appellate scheme with a limited condonable period, especially in tax matters where diligence is required. In the absence of a proper explanation for delay or any patent illegality, the petition was dismissed, with liberty to proceed in accordance with law and without affecting any future appeal.
Writ jurisdiction was not entertained to challenge GST proceedings after the statutory appeal period had expired, because the petitioner had replied to the show cause notice and been heard, so jurisdictional error and breach of natural justice were not established. The High Court held that Article 226 cannot be used to bypass a special appellate scheme with a limited condonable period, especially in tax matters where diligence is required. In the absence of a proper explanation for delay or any patent illegality, the petition was dismissed, with liberty to proceed in accordance with law and without affecting any future appeal.
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