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 High Court held that the Notification No. 9/2023 dated 31-03-2023, extending the time limit u/s 168A of the CGST Act, was valid and cannot be faulted. The explanation to Section 168A empowers the Government to extend time limits on the recommendation of the GST Council. The Council's decision was based on representations, increased workload due to Covid-19, and the inability to complete proceedings by 30-09-2023. The Court distinguished the Supreme Court's order on extending limitation periods before courts/tribunals, finding it inapplicable to tax authorities' actions like assessments or show cause notices. The petition challenging the notification was dismissed as no grounds were made out.
The High Court held that the Notification No. 9/2023 dated 31-03-2023, extending the time limit u/s 168A of the CGST Act, was valid and cannot be faulted. The explanation to Section 168A empowers the Government to extend time limits on the recommendation of the GST Council. The Council's decision was based on representations, increased workload due to Covid-19, and the inability to complete proceedings by 30-09-2023. The Court distinguished the Supreme Court's order on extending limitation periods before courts/tribunals, finding it inapplicable to tax authorities' actions like assessments or show cause notices. The petition challenging the notification was dismissed as no grounds were made out.
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