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...
Jurisdiction to condone delay in filing GST Appeal. Suspension of registration. Petitioner's lapse in not submitting tax returns for six consecutive months. Impugned order would prevent Petitioner from conducting business, necessitating fresh registration. Allowing re-hearing before State Tax Officer, subject to conditions for lapse, meets ends of justice. Petitioner's Accountant suffered from Covid-19 infection, preventing timely filing of returns. Token cost of Rs. 5,000/- imposed on Petitioner. Petition allowed in part.
Jurisdiction to condone delay in filing GST Appeal. Suspension of registration. Petitioner's lapse in not submitting tax returns for six consecutive months. Impugned order would prevent Petitioner from conducting business, necessitating fresh registration. Allowing re-hearing before State Tax Officer, subject to conditions for lapse, meets ends of justice. Petitioner's Accountant suffered from Covid-19 infection, preventing timely filing of returns. Token cost of Rs. 5,000/- imposed on Petitioner. Petition allowed in part.
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