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...
Maintainability of appeal against order under CGST/SGST Act adjudication on refund application dismissed. Appellant had option to pay amounts demanded or contest seizure and insist on adjudication order. Appellant chose payment, leading to release order without tax/penalty determination. If payment was mistake, appellant should have sought refund and adjudication on refund application. Appellant solely to blame for delay of over 7 years after release of goods. Writ Appeal dismissed, upholding Single Judge's dismissal of Writ Petition.
Maintainability of appeal against order under CGST/SGST Act adjudication on refund application dismissed. Appellant had option to pay amounts demanded or contest seizure and insist on adjudication order. Appellant chose payment, leading to release order without tax/penalty determination. If payment was mistake, appellant should have sought refund and adjudication on refund application. Appellant solely to blame for delay of over 7 years after release of goods. Writ Appeal dismissed, upholding Single Judge's dismissal of Writ Petition.
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