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...
HC set aside order imposing late fee on petitioner for delayed GSTR-9/9C filing before 01.04.2023, holding petitioner entitled to benefit of amnesty notification N/N. 07/2023 dated 31.03.2023 exempting late fee for filings between 01.04.2023-30.06.2023. HC ruled differential treatment violative of Article 14, directed withdrawal of impugned order/show cause notice, remanded for fresh order extending amnesty benefit to petitioner.
HC set aside order imposing late fee on petitioner for delayed GSTR-9/9C filing before 01.04.2023, holding petitioner entitled to benefit of amnesty notification N/N. 07/2023 dated 31.03.2023 exempting late fee for filings between 01.04.2023-30.06.2023. HC ruled differential treatment violative of Article 14, directed withdrawal of impugned order/show cause notice, remanded for fresh order extending amnesty benefit to petitioner.
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