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...
Adjudication of SCN after 17 years - The High Court ruled that the belated adjudication of the show cause notice rendered it arbitrary and illegal. Citing the principle established in the case of Coventry Estates Pvt. Ltd. vs. The Joint Commissioner, CGST and Central Excise and Anr. 2023, the Court held that such a prolonged delay in adjudication violates legal principles.
Adjudication of SCN after 17 years - The High Court ruled that the belated adjudication of the show cause notice rendered it arbitrary and illegal. Citing the principle established in the case of Coventry Estates Pvt. Ltd. vs. The Joint Commissioner, CGST and Central Excise and Anr. 2023, the Court held that such a prolonged delay in adjudication violates legal principles.
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