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 allowed the writ petition by quashing the appellate order dated June 28, 2024, due to procedural irregularities and arbitrary actions in the demand of tax, interest, and penalties u/ss 16(2)(c) and 73 of the GST Act. The Court held that provisions on limitation should be interpreted liberally where genuine hardships are demonstrated, considering judicial precedents supporting such relief. The Court found the petitioner's case meritorious in light of the procedural irregularities and arbitrary nature of the actions taken by the authorities.
The High Court allowed the writ petition by quashing the appellate order dated June 28, 2024, due to procedural irregularities and arbitrary actions in the demand of tax, interest, and penalties u/ss 16(2)(c) and 73 of the GST Act. The Court held that provisions on limitation should be interpreted liberally where genuine hardships are demonstrated, considering judicial precedents supporting such relief. The Court found the petitioner's case meritorious in light of the procedural irregularities and arbitrary nature of the actions taken by the authorities.
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