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...
Denial of input tax credit - demand of differential input tax - The court notes the discrepancy in the GST numbers but suggests the petitioner could obtain certification from the supplier to validate the transactions. However, the petitioner filed belated returns and paid taxes late, which led to the issuance of a show cause notice. The court finds no merit in the petitioner's argument regarding the imposition of penalties, emphasizing the belated payment of taxes and interest. - While dismissing the writ petition, the court grants the petitioner liberty to file an appeal within 30 days from the receipt of the order.
Denial of input tax credit - demand of differential input tax - The court notes the discrepancy in the GST numbers but suggests the petitioner could obtain certification from the supplier to validate the transactions. However, the petitioner filed belated returns and paid taxes late, which led to the issuance of a show cause notice. The court finds no merit in the petitioner's argument regarding the imposition of penalties, emphasizing the belated payment of taxes and interest. - While dismissing the writ petition, the court grants the petitioner liberty to file an appeal within 30 days from the receipt of the order.
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