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 appeal - time limitation - Cancellation of GST registration of petitioner - failure to submit GST returns for a continuous period of six months - Despite the dismissal of the appeal on limitation grounds, the Court asserted its jurisdiction to review the original authority's decision. Recognizing the petitioner's genuine reasons and societal contributions, the Court set aside the cancellation order, directing the authority to reconsider the revocation request with reasonable opportunity for the petitioner.
Maintainability of appeal - time limitation - Cancellation of GST registration of petitioner - failure to submit GST returns for a continuous period of six months - Despite the dismissal of the appeal on limitation grounds, the Court asserted its jurisdiction to review the original authority's decision. Recognizing the petitioner's genuine reasons and societal contributions, the Court set aside the cancellation order, directing the authority to reconsider the revocation request with reasonable opportunity for the petitioner.
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