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 quashed a letter dated March 13, 2024, issued by the Superintendent (A.E.) Central Goods and Service Tax, Gautam Budh Nagar, advising voluntary tax payments without proper legal basis. The Court observed that the Department was advising the petitioner to make voluntary payments without issuing any show cause notice/demand notice/recovery notice, which is unknown in law. The respondents failed to indicate any provision under which such a letter could be issued. The Court directed the authorities to be cautious and refrain from issuing such letters tantamounting to pressure tactics, allowing the petition.
The High Court quashed a letter dated March 13, 2024, issued by the Superintendent (A.E.) Central Goods and Service Tax, Gautam Budh Nagar, advising voluntary tax payments without proper legal basis. The Court observed that the Department was advising the petitioner to make voluntary payments without issuing any show cause notice/demand notice/recovery notice, which is unknown in law. The respondents failed to indicate any provision under which such a letter could be issued. The Court directed the authorities to be cautious and refrain from issuing such letters tantamounting to pressure tactics, allowing the petition.
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