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...
Validity of SCN issued u/s 73 of CGST Act challenged - recovery of demand of differential tax for tax period from 1-7-2017 to 31-12-2018 - transactions related to licensing services for right to use minerals including exploration and evaluation under Service Code 9973 37 - retrospective operation of CBIC circular dated 6-10-2021 - High Court issued notice to Opposite Parties - directed no coercive action for recovery of demand till next date of hearing - matter listed along with related writ petition.
Validity of SCN issued u/s 73 of CGST Act challenged - recovery of demand of differential tax for tax period from 1-7-2017 to 31-12-2018 - transactions related to licensing services for right to use minerals including exploration and evaluation under Service Code 9973 37 - retrospective operation of CBIC circular dated 6-10-2021 - High Court issued notice to Opposite Parties - directed no coercive action for recovery of demand till next date of hearing - matter listed along with related writ petition.
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