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, while acknowledging the procedural deficiency of not issuing GST RFD-03 to the petitioner, held that the petitioner failed to avail the opportunity to raise such contentions in response to the show cause notice. However, considering the peculiar circumstances and the non-issuance of GST RFD-03, the Court set aside the impugned order dated 30 April 2024, subject to the petitioner paying costs of Rs. 2,00,000/- within 4 weeks, and restored the petitioner's refund application made in form GST RFD-01.
The High Court, while acknowledging the procedural deficiency of not issuing GST RFD-03 to the petitioner, held that the petitioner failed to avail the opportunity to raise such contentions in response to the show cause notice. However, considering the peculiar circumstances and the non-issuance of GST RFD-03, the Court set aside the impugned order dated 30 April 2024, subject to the petitioner paying costs of Rs. 2,00,000/- within 4 weeks, and restored the petitioner's refund application made in form GST RFD-01.
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