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...
The petition is dismissed as an alternative efficacious remedy is available to challenge the impugned order u/s 107 of the GST Act. While violation of natural justice and vires of Section 16(2)(c) are grounds to entertain the writ, disputed questions of fact regarding opportunity of hearing and composite invocation of Section 16(2)(b) and 16(2)(c) necessitate thorough analysis, precluding interference at this stage. The petitioner can raise contentions on merits, including interpretation of Section 16(2)(b) read with Rule 36 and Section 155, before the Appellate Authority u/s 107.
The petition is dismissed as an alternative efficacious remedy is available to challenge the impugned order u/s 107 of the GST Act. While violation of natural justice and vires of Section 16(2)(c) are grounds to entertain the writ, disputed questions of fact regarding opportunity of hearing and composite invocation of Section 16(2)(b) and 16(2)(c) necessitate thorough analysis, precluding interference at this stage. The petitioner can raise contentions on merits, including interpretation of Section 16(2)(b) read with Rule 36 and Section 155, before the Appellate Authority u/s 107.
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