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...
Wrong availment of transitional Input Tax Credit - request for an adjournment was not responded to - The Court acknowledged that although a personal hearing was offered under the reminder dated 16.12.2023, the subsequent issuance of the impugned order without considering the petitioner's adjournment request rendered the order unsustainable. Consequently, the High Court quashed the impugned order and remanded the matter for reconsideration.
Wrong availment of transitional Input Tax Credit - request for an adjournment was not responded to - The Court acknowledged that although a personal hearing was offered under the reminder dated 16.12.2023, the subsequent issuance of the impugned order without considering the petitioner's adjournment request rendered the order unsustainable. Consequently, the High Court quashed the impugned order and remanded the matter for reconsideration.
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