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...
Summary in relevant legal terminology: Petitioner's plea to quash show-cause notice and corrigendum citing non-compliance with Rule 142 of GST Rules, 2017 was dismissed. Court observed that the notices clearly detailed tax liabilities, enabling petitioner to effectively contest facts. No violation of principles of natural justice occurred. Petitioner has liberty to pursue statutory appeal against impugned annexures before Appellate Authority.
Summary in relevant legal terminology: Petitioner's plea to quash show-cause notice and corrigendum citing non-compliance with Rule 142 of GST Rules, 2017 was dismissed. Court observed that the notices clearly detailed tax liabilities, enabling petitioner to effectively contest facts. No violation of principles of natural justice occurred. Petitioner has liberty to pursue statutory appeal against impugned annexures before Appellate Authority.
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