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...
Impugned order quashed and matter remanded for fresh consideration. HC found non-application of mind, non-consideration of Petitioner's reply to show cause notice, and lack of reasoning in passing order u/s 168-A of CGST Act read with DGST Act for failure to declare correct tax liability in GSTR-09. Relying on coordinate bench judgments in Indian Highways and Chetak Logistic, HC held impugned order untenable for being passed in cavalier manner without deciding on merits, thereby violating principles of natural justice.
Impugned order quashed and matter remanded for fresh consideration. HC found non-application of mind, non-consideration of Petitioner's reply to show cause notice, and lack of reasoning in passing order u/s 168-A of CGST Act read with DGST Act for failure to declare correct tax liability in GSTR-09. Relying on coordinate bench judgments in Indian Highways and Chetak Logistic, HC held impugned order untenable for being passed in cavalier manner without deciding on merits, thereby violating principles of natural justice.
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