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...
Constitutional validity of Rule 86A of the CGST/SGST Rules, 2017, which was challenged for violating Articles 14 and 19(1)(g) of the Constitution of India. The court held that since no pre-decisional hearing was granted before passing the impugned order blocking the petitioner's electronic credit ledger, and the order lacked independent or cogent reasons except relying on the enforcement authority's reports, which is impermissible as it constitutes borrowed satisfaction, the impugned order deserved to be quashed. Consequently, the High Court quashed the impugned order dated 23.01.2020 and directed the respondents to unblock the petitioner's electronic credit ledger immediately to enable the petitioner to file returns forthwith, allowing the petition.
Constitutional validity of Rule 86A of the CGST/SGST Rules, 2017, which was challenged for violating Articles 14 and 19(1)(g) of the Constitution of India. The court held that since no pre-decisional hearing was granted before passing the impugned order blocking the petitioner's electronic credit ledger, and the order lacked independent or cogent reasons except relying on the enforcement authority's reports, which is impermissible as it constitutes borrowed satisfaction, the impugned order deserved to be quashed. Consequently, the High Court quashed the impugned order dated 23.01.2020 and directed the respondents to unblock the petitioner's electronic credit ledger immediately to enable the petitioner to file returns forthwith, allowing the petition.
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