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...
The court found the petition maintainable despite the time limitation, as the petitioner failed to notice the show cause notice (SCN) posted on the GST common portal. Partial relief was granted by quashing the impugned order and remitting the case back to the respondent for fresh orders, subject to the petitioner depositing 10% of the disputed tax from its Electronic Cash Register. The quashed order shall be treated as an addendum to the preceding show cause notice.
The court found the petition maintainable despite the time limitation, as the petitioner failed to notice the show cause notice (SCN) posted on the GST common portal. Partial relief was granted by quashing the impugned order and remitting the case back to the respondent for fresh orders, subject to the petitioner depositing 10% of the disputed tax from its Electronic Cash Register. The quashed order shall be treated as an addendum to the preceding show cause notice.
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