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 addressed the validity of a show cause notice (SCN) and final order issued against a non-existent entity, the rectification of procedural defects, and the applicability of Sections 160 and 87 of the CGST Act, 2017, concerning amalgamated companies. Section 87 seeks to preserve and identify transactions between companies that ultimately amalgamate, fixing liabilities under the CGST Act. However, it cannot enable issuing notices or orders against a non-existent entity, as the liabilities would transpose to the amalgamated entity. Consequently, the impugned SCN and order were quashed, and the petition was allowed.
The High Court addressed the validity of a show cause notice (SCN) and final order issued against a non-existent entity, the rectification of procedural defects, and the applicability of Sections 160 and 87 of the CGST Act, 2017, concerning amalgamated companies. Section 87 seeks to preserve and identify transactions between companies that ultimately amalgamate, fixing liabilities under the CGST Act. However, it cannot enable issuing notices or orders against a non-existent entity, as the liabilities would transpose to the amalgamated entity. Consequently, the impugned SCN and order were quashed, and the petition was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
