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...
Demand on account of alleged delay in availing Input Tax Credit purportedly Rs. 23,35,892/- out of Rs. 57,12,114/-. Impugned order set aside to that extent, case remitted to consider proposals in GST Council's 53rd Meeting and Finance (No.2) Bill, 2024 (Bill No.55 of 2024) Clause 114 & 146. For balance amount Rs. 33,76,222/-, petitioner given liberty to file statutory appeal within 30 days. Petition disposed.
Demand on account of alleged delay in availing Input Tax Credit purportedly Rs. 23,35,892/- out of Rs. 57,12,114/-. Impugned order set aside to that extent, case remitted to consider proposals in GST Council's 53rd Meeting and Finance (No.2) Bill, 2024 (Bill No.55 of 2024) Clause 114 & 146. For balance amount Rs. 33,76,222/-, petitioner given liberty to file statutory appeal within 30 days. Petition disposed.
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