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...
Proper officer - Jurisdiction of Initiate investigation proceedings by the Central GST and State GST authorities simultaneously - cross-empowerment - The Court found that in the absence of specific notifications enabling cross-empowerment, except for purposes related to tax refunds, the proceedings initiated by an authority (either Central or State) against taxpayers not assigned to them are without jurisdiction. - While the Court quashed the impugned proceedings for lacking jurisdiction, it also directed the respective authorities (Central or State) to whom the petitioners are administratively assigned to initiate fresh proceedings, if warranted, in compliance with the applicable laws and regulations. The period during which the impugned proceedings were initiated and pending litigation was to be excluded from the calculation of any limitation period for initiating new proceedings.
Proper officer - Jurisdiction of Initiate investigation proceedings by the Central GST and State GST authorities simultaneously - cross-empowerment - The Court found that in the absence of specific notifications enabling cross-empowerment, except for purposes related to tax refunds, the proceedings initiated by an authority (either Central or State) against taxpayers not assigned to them are without jurisdiction. - While the Court quashed the impugned proceedings for lacking jurisdiction, it also directed the respective authorities (Central or State) to whom the petitioners are administratively assigned to initiate fresh proceedings, if warranted, in compliance with the applicable laws and regulations. The period during which the impugned proceedings were initiated and pending litigation was to be excluded from the calculation of any limitation period for initiating new proceedings.
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