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...
Tax authority's action of blocking input tax credit in electronic credit ledger without following due process held untenable. Cross-utilization of credit between CGST and SGST not permissible. Respondents directed to unblock credit of Rs. 2,44,05,567 in petitioners' electronic credit ledger. Utilization of remaining credit disallowed till show cause notice issued under relevant provisions of GST Act. Petition allowed.
Tax authority's action of blocking input tax credit in electronic credit ledger without following due process held untenable. Cross-utilization of credit between CGST and SGST not permissible. Respondents directed to unblock credit of Rs. 2,44,05,567 in petitioners' electronic credit ledger. Utilization of remaining credit disallowed till show cause notice issued under relevant provisions of GST Act. Petition allowed.
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