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...
Validity of demand of GST - For assessment year 2017-2018 - Notice in Form ASMT-10 issued for discrepancies found in returns - proceedings initiated pursuant to notice in Form ASMT-10, dropped by issuing an order in Form ASMT-12 - demand towards IGST, SGST and CGST - whether the same demand was resurrected - The court finds that the impugned assessment order confirms demands for the same assessment period and amounts, with the addition of interest and penalty. Given the previous conclusion that no further action was required, the continuation of proceedings leading to the impugned assessment order is deemed unsustainable.
Validity of demand of GST - For assessment year 2017-2018 - Notice in Form ASMT-10 issued for discrepancies found in returns - proceedings initiated pursuant to notice in Form ASMT-10, dropped by issuing an order in Form ASMT-12 - demand towards IGST, SGST and CGST - whether the same demand was resurrected - The court finds that the impugned assessment order confirms demands for the same assessment period and amounts, with the addition of interest and penalty. Given the previous conclusion that no further action was required, the continuation of proceedings leading to the impugned assessment order is deemed unsustainable.
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