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...
Petition challenging Circular No.151/07/2021-GST as ultra vires provisions of entry at Serial No.66(a) read with Paragraph 2(y) of N/N. 12/2017-Central Tax (Rate) and corresponding Delhi GST Act notifications. Petitioner alleged refund rejection order dated 29.06.2022 was passed without considering submissions and denying personal hearing, violating natural justice. High Court disposed petition as part of batch matters, setting aside impugned refund rejection orders. Matter remanded to appropriate authority for fresh consideration.
Petition challenging Circular No.151/07/2021-GST as ultra vires provisions of entry at Serial No.66(a) read with Paragraph 2(y) of N/N. 12/2017-Central Tax (Rate) and corresponding Delhi GST Act notifications. Petitioner alleged refund rejection order dated 29.06.2022 was passed without considering submissions and denying personal hearing, violating natural justice. High Court disposed petition as part of batch matters, setting aside impugned refund rejection orders. Matter remanded to appropriate authority for fresh consideration.
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