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...
Petitioner challenged notices issued in Form GST MOV-01 and MOV-07 for not generating e-invoices during transfer of PETN explosives. Court held that petitioner undertook to pay penalty and did not assert goods were exempted. Exemption is a mixed question of fact and law to be examined by respondent. Since notices were issued and petitioner replied, adjudication process should be concluded. Petition disposed of directing respondent to conclude adjudication within four weeks and petitioner permitted to submit reply to revised notice within one week.
Petitioner challenged notices issued in Form GST MOV-01 and MOV-07 for not generating e-invoices during transfer of PETN explosives. Court held that petitioner undertook to pay penalty and did not assert goods were exempted. Exemption is a mixed question of fact and law to be examined by respondent. Since notices were issued and petitioner replied, adjudication process should be concluded. Petition disposed of directing respondent to conclude adjudication within four weeks and petitioner permitted to submit reply to revised notice within one week.
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