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...
Impugned order passed without reasons based on Special Audit Report, violating principles of natural justice. Order lacks analysis on contentious issues regarding mismatch between GST returns and credit entries in bank account, merely confirming demand in show-cause notice. Adjudicating Authority failed to consider contentious issues. Matter remanded for fresh consideration. Petition allowed by way of remand.
Impugned order passed without reasons based on Special Audit Report, violating principles of natural justice. Order lacks analysis on contentious issues regarding mismatch between GST returns and credit entries in bank account, merely confirming demand in show-cause notice. Adjudicating Authority failed to consider contentious issues. Matter remanded for fresh consideration. Petition allowed by way of remand.
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