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...
Petitioner is owner of goods being transported as stock transfer from Orissa branch to Kanpur. HC held that when goods were intercepted, requisite documents under GST Act were accompanied and no discrepancy found regarding quantity, except in e-way bill transferee place was mentioned as Ghaziabad while in tax invoice it was Kanpur. As petitioner is consignor and consignee, being stock transfer, petitioner ought to have been treated as owner. Following SC judgment in Arviva Industries case and HC's own judgment in Riya Traders case, authorities were not justified in not recognizing petitioner as owner evident from record. Impugned orders quashed, petition allowed.
Petitioner is owner of goods being transported as stock transfer from Orissa branch to Kanpur. HC held that when goods were intercepted, requisite documents under GST Act were accompanied and no discrepancy found regarding quantity, except in e-way bill transferee place was mentioned as Ghaziabad while in tax invoice it was Kanpur. As petitioner is consignor and consignee, being stock transfer, petitioner ought to have been treated as owner. Following SC judgment in Arviva Industries case and HC's own judgment in Riya Traders case, authorities were not justified in not recognizing petitioner as owner evident from record. Impugned orders quashed, petition allowed.
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