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 appeal was initially rejected on the ground of limitation due to the non-availability of a self-attested copy of the order within the stipulated time frame as per Rule 108 of the UPGST/CGST Rules. However, the High Court, relying on the precedent set in the case of Visible Alpha Solutions India Private Limited, held that an appeal cannot be dismissed solely on the ground of limitation for non-filing of a certified copy of the order. Consequently, the impugned order was quashed, and the matter was remanded to the concerned authority for a fresh decision within two months, after hearing all stakeholders and passing a reasoned and speaking order.
The appeal was initially rejected on the ground of limitation due to the non-availability of a self-attested copy of the order within the stipulated time frame as per Rule 108 of the UPGST/CGST Rules. However, the High Court, relying on the precedent set in the case of Visible Alpha Solutions India Private Limited, held that an appeal cannot be dismissed solely on the ground of limitation for non-filing of a certified copy of the order. Consequently, the impugned order was quashed, and the matter was remanded to the concerned authority for a fresh decision within two months, after hearing all stakeholders and passing a reasoned and speaking order.
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