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 impugned order u/s 73 of the CGST Act - The case before the Calcutta High Court involved a challenge to an order issued under the CGST Act, wherein the petitioner alleged fraudulent manipulation of their taxpayer login credentials. Despite the serious criminal nature of the allegations, the Court held that such matters fell outside the ambit of constitutional writ jurisdiction under Article 226. It emphasized the availability of statutory appeal against the impugned order and dismissed the petitioner's plea, citing the lack of grounds to justify intervention by the writ court.
Validity of impugned order u/s 73 of the CGST Act - The case before the Calcutta High Court involved a challenge to an order issued under the CGST Act, wherein the petitioner alleged fraudulent manipulation of their taxpayer login credentials. Despite the serious criminal nature of the allegations, the Court held that such matters fell outside the ambit of constitutional writ jurisdiction under Article 226. It emphasized the availability of statutory appeal against the impugned order and dismissed the petitioner's plea, citing the lack of grounds to justify intervention by the writ court.
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