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...
Maintainability of petition - appealable order or not - Levy of interest under Section 50 along with penalty under Section 122(2) of the Central Goods and Service Tax Act, 2017 - restriction on ITC - Since an appeal provision is available, it is in the fitness, it would be just and proper, the petitioner avails the remedy of appeal where all the issues can be agitated. - HC
Maintainability of petition - appealable order or not - Levy of interest under Section 50 along with penalty under Section 122(2) of the Central Goods and Service Tax Act, 2017 - restriction on ITC - Since an appeal provision is available, it is in the fitness, it would be just and proper, the petitioner avails the remedy of appeal where all the issues can be agitated. - HC
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