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...
Cancellation of GST registration does not extinguish tax liability for periods preceding cancellation. High Court found that the taxpayer received the show-cause notice and statutory forms through the common portal and had repeated opportunities to respond and attend a personal hearing, but did not do so. No defect justified writ interference with the assessment order imposing tax and penalty. The writ petition was disposed of without interference, while preserving liberty to file a statutory appeal within the prescribed period on payment of the statutory pre-deposit.
Cancellation of GST registration does not extinguish tax liability for periods preceding cancellation. High Court found that the taxpayer received the show-cause notice and statutory forms through the common portal and had repeated opportunities to respond and attend a personal hearing, but did not do so. No defect justified writ interference with the assessment order imposing tax and penalty. The writ petition was disposed of without interference, while preserving liberty to file a statutory appeal within the prescribed period on payment of the statutory pre-deposit.
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