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 is ordinarily not exercised in tax matters where an efficacious statutory appeal exists, and the petitioner's challenges to classification, exemption, annuity receipts, composite supply, notifications and circulars were held to fall within the appellate framework. The Court found no exceptional ground such as patent lack of jurisdiction or violation of natural justice, noting that the petitioner had participated in adjudication and was heard. It also held that the Additional Director, DGGI, and the Additional Commissioner, CGST, were validly empowered as proper officers under the statutory notifications to issue the notice and adjudicate it. The writ petition was dismissed with liberty to pursue the statutory appeal.
Writ jurisdiction is ordinarily not exercised in tax matters where an efficacious statutory appeal exists, and the petitioner's challenges to classification, exemption, annuity receipts, composite supply, notifications and circulars were held to fall within the appellate framework. The Court found no exceptional ground such as patent lack of jurisdiction or violation of natural justice, noting that the petitioner had participated in adjudication and was heard. It also held that the Additional Director, DGGI, and the Additional Commissioner, CGST, were validly empowered as proper officers under the statutory notifications to issue the notice and adjudicate it. The writ petition was dismissed with liberty to pursue the statutory appeal.
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