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 HC upheld the blocking of account and Input Tax Credit u/s 74 of the CGST Act, 2017 for wrongful availment of ITC showing fake invoices as the concerned firms were found non-existent. Section 86-A was rightly exercised based on prima facie view without issuing show cause notice to protect revenue. However, the HC directed respondents to pass final order expeditiously, preferably within one month, and allowed petitioner to operate account as over 1.5 years elapsed since blocking.
The HC upheld the blocking of account and Input Tax Credit u/s 74 of the CGST Act, 2017 for wrongful availment of ITC showing fake invoices as the concerned firms were found non-existent. Section 86-A was rightly exercised based on prima facie view without issuing show cause notice to protect revenue. However, the HC directed respondents to pass final order expeditiously, preferably within one month, and allowed petitioner to operate account as over 1.5 years elapsed since blocking.
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