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...
Inadmissible ITC utilization from cancelled suppliers - petitioner disclosed inward tax supply invoices, party ledger, bank statements, GSTR-2A and e-waybills for supplies allegedly made by a supplier during September-October 2017. Although petitioner discharged initial burden of proof, appellate authority found petitioner ineligible for ITC without specifying documents required to establish transaction genuineness. Appellate authority's order suffered from non-application of mind, being verbatim reproduction of adjudicating authority's observations. Matter remanded to appellate authority to reconsider issue of movement of goods and indicate documents petitioner required to disclose for establishing transaction genuineness. Petition allowed by way of remand.
Inadmissible ITC utilization from cancelled suppliers - petitioner disclosed inward tax supply invoices, party ledger, bank statements, GSTR-2A and e-waybills for supplies allegedly made by a supplier during September-October 2017. Although petitioner discharged initial burden of proof, appellate authority found petitioner ineligible for ITC without specifying documents required to establish transaction genuineness. Appellate authority's order suffered from non-application of mind, being verbatim reproduction of adjudicating authority's observations. Matter remanded to appellate authority to reconsider issue of movement of goods and indicate documents petitioner required to disclose for establishing transaction genuineness. Petition allowed by way of remand.
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