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 a supplier's GST registration or closure of business does not, by itself, defeat a purchaser's input tax credit entitlement; the department must establish collusion between the supplier and purchaser. Alleged fraudulent input tax credit availment was not prima facie supported where there was no material showing foundational supplier violations, and subsequent supplier non-existence or registration cancellation was insufficient. Anticipatory bail was granted because the petitioners lacked criminal antecedents, had appeared before authorities, and undertook to cooperate and produce documents; custodial interrogation was not warranted merely because the allegations involved an economic offence. Release was subject to investigation-cooperation and appearance conditions.
Cancellation of a supplier's GST registration or closure of business does not, by itself, defeat a purchaser's input tax credit entitlement; the department must establish collusion between the supplier and purchaser. Alleged fraudulent input tax credit availment was not prima facie supported where there was no material showing foundational supplier violations, and subsequent supplier non-existence or registration cancellation was insufficient. Anticipatory bail was granted because the petitioners lacked criminal antecedents, had appeared before authorities, and undertook to cooperate and produce documents; custodial interrogation was not warranted merely because the allegations involved an economic offence. Release was subject to investigation-cooperation and appearance conditions.
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