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 against a GST demand was not considered appropriate where allegations of fraudulent registration, identity theft and forgery created disputed factual questions requiring evidence. As the impugned order addressed the taxpayers' submissions after a hearing, its factual findings were suitable for review by the statutory appellate authority. The High Court therefore declined to examine the merits and directed the taxpayers to pursue the available statutory appeal, with liberty to seek exclusion of the time spent prosecuting the writ petition for limitation purposes.
Writ jurisdiction against a GST demand was not considered appropriate where allegations of fraudulent registration, identity theft and forgery created disputed factual questions requiring evidence. As the impugned order addressed the taxpayers' submissions after a hearing, its factual findings were suitable for review by the statutory appellate authority. The High Court therefore declined to examine the merits and directed the taxpayers to pursue the available statutory appeal, with liberty to seek exclusion of the time spent prosecuting the writ petition for limitation purposes.
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