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...
Duplicate assessment orders arising from the same GSTR-3B and GSTR-1 return mismatch cannot coexist where both concern the same assessment period and identical tax liability. The later order was quashed because it duplicated the earlier assessment, notwithstanding the absence of an SGST-CGST bifurcation. The earlier assessment order was set aside and remanded for fresh consideration to provide a reasonable opportunity to contest the tax proposal on merits. That remand was conditional on payment of the entire tax demand within the stipulated period.
Duplicate assessment orders arising from the same GSTR-3B and GSTR-1 return mismatch cannot coexist where both concern the same assessment period and identical tax liability. The later order was quashed because it duplicated the earlier assessment, notwithstanding the absence of an SGST-CGST bifurcation. The earlier assessment order was set aside and remanded for fresh consideration to provide a reasonable opportunity to contest the tax proposal on merits. That remand was conditional on payment of the entire tax demand within the stipulated period.
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