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...
Reversal of input tax credit (ITC) u/s 17(5)(h) of the CGST Act, 2017 can be sought on presumptive basis or not - Allegation of short declaration of Outward Supply and excess claim of ITC - The High court concludes that the issuance of the Show Cause Notice is arbitrary due to procedural irregularities, including inadequate consideration of the petitioner's submissions. - The petitioner is granted relief in part, with the quashing of the impugned Show Cause Notice, but with certain liberties granted to both parties for further submissions and actions.
Reversal of input tax credit (ITC) u/s 17(5)(h) of the CGST Act, 2017 can be sought on presumptive basis or not - Allegation of short declaration of Outward Supply and excess claim of ITC - The High court concludes that the issuance of the Show Cause Notice is arbitrary due to procedural irregularities, including inadequate consideration of the petitioner's submissions. - The petitioner is granted relief in part, with the quashing of the impugned Show Cause Notice, but with certain liberties granted to both parties for further submissions and actions.
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