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...
Proceedings initiated by State Authority u/s 74 are valid even if Central Authority has already initiated proceedings. The term 'initiation of proceedings' refers to issuance of notice under CGST/SGST Acts, not issuance of summons u/s 70 for inquiry. The Patna High Court's judgment in Baibhaw Construction did not consider this aspect. Therefore, the petitions lack merit and are dismissed.
Proceedings initiated by State Authority u/s 74 are valid even if Central Authority has already initiated proceedings. The term 'initiation of proceedings' refers to issuance of notice under CGST/SGST Acts, not issuance of summons u/s 70 for inquiry. The Patna High Court's judgment in Baibhaw Construction did not consider this aspect. Therefore, the petitions lack merit and are dismissed.
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