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 petitioners have no right of appeal against the determination made by the authority regarding the profited amount u/s 171 of the CGST Act. However, as an interim relief, the Court granted a conditional stay, subject to the petitioners depositing 50% of the profited amount, excluding interest, within 8 weeks. The Court observed that granting such conditional stay would serve the interests of justice in the present case.
The High Court held that the petitioners have no right of appeal against the determination made by the authority regarding the profited amount u/s 171 of the CGST Act. However, as an interim relief, the Court granted a conditional stay, subject to the petitioners depositing 50% of the profited amount, excluding interest, within 8 weeks. The Court observed that granting such conditional stay would serve the interests of justice in the present case.
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