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...
Notification No. 56/2023 prima facie appears ultra vires Section 168A of CGST Act, 2017 due to lack of GST Council recommendation, rendering consequential actions based on it invalid. Court finds examination required regarding force majeure applicability based on 49th GST Council meeting minutes, granting respondent authorities opportunity to present stance and materials. Interim protection granted to petitioners against impugned assessment order dated 26.04.2024 with no coercive action permitted until next date. Respondents directed to file affidavits by 19.08.2024.
Notification No. 56/2023 prima facie appears ultra vires Section 168A of CGST Act, 2017 due to lack of GST Council recommendation, rendering consequential actions based on it invalid. Court finds examination required regarding force majeure applicability based on 49th GST Council meeting minutes, granting respondent authorities opportunity to present stance and materials. Interim protection granted to petitioners against impugned assessment order dated 26.04.2024 with no coercive action permitted until next date. Respondents directed to file affidavits by 19.08.2024.
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