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...
An efficacious statutory appeal generally bars writ jurisdiction against an appealable GST adjudication order unless exceptional circumstances are properly pleaded and supported. A natural justice challenge based on non-supply of relied-upon documents requires particulars identifying the documents withheld and the resulting prejudice; a bare allegation is insufficient, particularly where the order records service of the show cause notice and documents through registered and other email addresses. The article notes that writ petitions should not be used to bypass the appellate process or mandatory pre-deposit. The petition was treated as not maintainable, with liberty to pursue the statutory appeal subject to statutory requirements and with merits left open.
An efficacious statutory appeal generally bars writ jurisdiction against an appealable GST adjudication order unless exceptional circumstances are properly pleaded and supported. A natural justice challenge based on non-supply of relied-upon documents requires particulars identifying the documents withheld and the resulting prejudice; a bare allegation is insufficient, particularly where the order records service of the show cause notice and documents through registered and other email addresses. The article notes that writ petitions should not be used to bypass the appellate process or mandatory pre-deposit. The petition was treated as not maintainable, with liberty to pursue the statutory appeal subject to statutory requirements and with merits left open.
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