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...
High Court rejected petitioner's writ petition challenging refund rejection order, observing that respondent authority had passed reasoned order after considering petitioner's reply and deficiencies in refund application. Court held that petitioner ought to have availed statutory appeal remedy instead of directly approaching Court. Under Article 226, High Court's jurisdiction in certiorari is supervisory, limited to correcting errors of jurisdiction or natural justice violations, not re-appreciating evidence. Appellate forum offers wider canvas than writ jurisdiction. Petition dismissed, with liberty to pursue statutory appeal.
High Court rejected petitioner's writ petition challenging refund rejection order, observing that respondent authority had passed reasoned order after considering petitioner's reply and deficiencies in refund application. Court held that petitioner ought to have availed statutory appeal remedy instead of directly approaching Court. Under Article 226, High Court's jurisdiction in certiorari is supervisory, limited to correcting errors of jurisdiction or natural justice violations, not re-appreciating evidence. Appellate forum offers wider canvas than writ jurisdiction. Petition dismissed, with liberty to pursue statutory appeal.
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