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 rejected solely on non-compliance of time limit u/s 34(2) of Central Goods and Services Tax Act, 2017. Appellant authority noted facts, grounds, submissions but dismissed appeal without addressing misinterpretation of Section 34(2) raised by appellants. High Court quashed orders of authorities, remanded matter to consider refund application u/s 54 based on documents, undisputed TPL certificate, and pass order in accordance with law. Petition disposed.
Refund claim rejected solely on non-compliance of time limit u/s 34(2) of Central Goods and Services Tax Act, 2017. Appellant authority noted facts, grounds, submissions but dismissed appeal without addressing misinterpretation of Section 34(2) raised by appellants. High Court quashed orders of authorities, remanded matter to consider refund application u/s 54 based on documents, undisputed TPL certificate, and pass order in accordance with law. Petition disposed.
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