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...
Demand under GST based solely on FORM 26AS entries could not be sustained where the sale deeds, if examined, indicated a prima facie sale of immovable property outside the GST levy. The HC found that the assessment proceeded on an assumed failure to produce the deeds, but once the copies of the sale deeds and corresponding FORM 26AS were considered, the underlying transaction required proper scrutiny. The impugned orders were quashed and the matter was remitted for fresh adjudication after notice.
Demand under GST based solely on FORM 26AS entries could not be sustained where the sale deeds, if examined, indicated a prima facie sale of immovable property outside the GST levy. The HC found that the assessment proceeded on an assumed failure to produce the deeds, but once the copies of the sale deeds and corresponding FORM 26AS were considered, the underlying transaction required proper scrutiny. The impugned orders were quashed and the matter was remitted for fresh adjudication after notice.
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