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...
Refund claim time limitation was challenged - Appeal filed online on GST portal on 31.10.2022 within prescribed period as per Rule 108(1) of GST Rules - Order appealed against was uploaded on common portal, thus filing hard copy not required u/r 108(3) proviso - Even otherwise, hard copy filing merely procedural - Impugned order rejecting appeal set aside, appellate authority directed to receive and dispose appeal on merits.
Refund claim time limitation was challenged - Appeal filed online on GST portal on 31.10.2022 within prescribed period as per Rule 108(1) of GST Rules - Order appealed against was uploaded on common portal, thus filing hard copy not required u/r 108(3) proviso - Even otherwise, hard copy filing merely procedural - Impugned order rejecting appeal set aside, appellate authority directed to receive and dispose appeal on merits.
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