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...
Registration cancellation under WB GST/CGST Act due to non-filing of returns. Appeal rejected as time-barred u/s 107(4). Court observed petitioner's case did not involve tax evasion or dubious activities. Suspension/revocation would be counterproductive, impacting revenue recovery as petitioner cannot raise invoices or carry on business. Respondents directed to take pragmatic view, allow petitioner to operate business subject to filing pending returns and paying requisite tax, interest, penalty. Order cancelling petitioner's registration set aside on condition of clearing arrears. Petition disposed.
Registration cancellation under WB GST/CGST Act due to non-filing of returns. Appeal rejected as time-barred u/s 107(4). Court observed petitioner's case did not involve tax evasion or dubious activities. Suspension/revocation would be counterproductive, impacting revenue recovery as petitioner cannot raise invoices or carry on business. Respondents directed to take pragmatic view, allow petitioner to operate business subject to filing pending returns and paying requisite tax, interest, penalty. Order cancelling petitioner's registration set aside on condition of clearing arrears. Petition disposed.
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