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 failed to substantiate Input Tax Credit claim due to lack of supplier certificates. Discrepancy noted between Input Tax Credit availed in GSTR 3B and auto-populated in GSTR 2A. Electronic Credit Ledger balance after adjustment indicates inadequate explanation. Petitioner's credit tax position appears incorrect, unable to avail claimed IGST amount under CGST and SGST credit. Court grants temporary relief, staying recovery proceedings for three months, allowing petitioner to file revision petition u/s 161 within 30 days. Petition disposed.
Petitioner failed to substantiate Input Tax Credit claim due to lack of supplier certificates. Discrepancy noted between Input Tax Credit availed in GSTR 3B and auto-populated in GSTR 2A. Electronic Credit Ledger balance after adjustment indicates inadequate explanation. Petitioner's credit tax position appears incorrect, unable to avail claimed IGST amount under CGST and SGST credit. Court grants temporary relief, staying recovery proceedings for three months, allowing petitioner to file revision petition u/s 161 within 30 days. Petition disposed.
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