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 dismissed the writ petition. The petitioner failed to file GSTR-3B returns and discharge the tax liability, despite having self-assessed and filed GSTR-1. The court held there was no scope for exercising discretion by extending the payment period, as the petitioner ought to have filed GSTR-3B and paid the tax. Furthermore, more than two years had elapsed since the impugned order dated 13.04.2022, providing ample time for the petitioner to pay the amount during the pendency of the writ petition.
The High Court dismissed the writ petition. The petitioner failed to file GSTR-3B returns and discharge the tax liability, despite having self-assessed and filed GSTR-1. The court held there was no scope for exercising discretion by extending the payment period, as the petitioner ought to have filed GSTR-3B and paid the tax. Furthermore, more than two years had elapsed since the impugned order dated 13.04.2022, providing ample time for the petitioner to pay the amount during the pendency of the writ petition.
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