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, upholding the tax authority's jurisdiction and power to issue the notice demanding tax and penalty. The court affirmed that u/s 4 of the IGST Act, officers of the State Tax are cross-authorized as proper officers for the purposes of the IGST Act, subject to any exceptions or conditions specified by the Government. As no such exceptions or conditions were notified, the appointment and powers of the State Tax officers empowered them to act under the IGST Act. Additionally, the court held that the prerogative to deem someone as the owner of the consignment lies with the revenue authorities.
The High Court dismissed the writ petition, upholding the tax authority's jurisdiction and power to issue the notice demanding tax and penalty. The court affirmed that u/s 4 of the IGST Act, officers of the State Tax are cross-authorized as proper officers for the purposes of the IGST Act, subject to any exceptions or conditions specified by the Government. As no such exceptions or conditions were notified, the appointment and powers of the State Tax officers empowered them to act under the IGST Act. Additionally, the court held that the prerogative to deem someone as the owner of the consignment lies with the revenue authorities.
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