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...
The High Court held that the Additional Director of GST Intelligence was competent to issue the communication demanding payment, rejecting the petitioner's contention that only an Assistant Commissioner could issue such a notice. The court relied on a circular permitting Central Tax Officers of Audit Commissionerates and Directorate General of GST to issue show-cause notices. The impugned communication was not a show-cause notice but merely an intimation to pay up, failing which a show-cause notice u/s 74(1) would be issued, for which the Additional Director was competent. The court found no reason to interfere with the communication and dismissed the petition.
The High Court held that the Additional Director of GST Intelligence was competent to issue the communication demanding payment, rejecting the petitioner's contention that only an Assistant Commissioner could issue such a notice. The court relied on a circular permitting Central Tax Officers of Audit Commissionerates and Directorate General of GST to issue show-cause notices. The impugned communication was not a show-cause notice but merely an intimation to pay up, failing which a show-cause notice u/s 74(1) would be issued, for which the Additional Director was competent. The court found no reason to interfere with the communication and dismissed the petition.
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