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 set aside the non-speaking order of the respondent and remitted the matter back for fresh consideration of the demand in the show cause notice and the petitioner's reply. The respondent failed to consider the petitioner's reconciliation report which showed excess credit of Rs. 1,40,684/- after adjusting IGST, CGST and SGST, violating principles of natural justice. The impugned order did not provide reasons for rejecting the petitioner's explanation. The petition was allowed by way of remand.
The HC set aside the non-speaking order of the respondent and remitted the matter back for fresh consideration of the demand in the show cause notice and the petitioner's reply. The respondent failed to consider the petitioner's reconciliation report which showed excess credit of Rs. 1,40,684/- after adjusting IGST, CGST and SGST, violating principles of natural justice. The impugned order did not provide reasons for rejecting the petitioner's explanation. The petition was allowed by way of remand.
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