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...
Rectification petition - Validity Of Order passed - discrepancy between the GSTR 3B return - The petitioner contended that the discrepancy arose due to the belated filing of GSTR 1 by the supplier for one invoice and asserted their inability to upload a reply on the GST portal. Supporting documents, including certificates from the supplier and their Chartered Accountant, were submitted but not considered in the impugned order. - The High Court found that the non-consideration of these documents was significant and warranted interference with the order. Consequently, the court set aside the order and remanded the matter to the respondent for reconsideration.
Rectification petition - Validity Of Order passed - discrepancy between the GSTR 3B return - The petitioner contended that the discrepancy arose due to the belated filing of GSTR 1 by the supplier for one invoice and asserted their inability to upload a reply on the GST portal. Supporting documents, including certificates from the supplier and their Chartered Accountant, were submitted but not considered in the impugned order. - The High Court found that the non-consideration of these documents was significant and warranted interference with the order. Consequently, the court set aside the order and remanded the matter to the respondent for reconsideration.
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