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 challenged SCN alleging conspiracy to issue fake invoices without actual supply using another entity's GST registration for tax evasion. HC held petitioner has remedy to file objection for adjudication on merits. Mere assertion of lack of jurisdiction or abuse of process insufficient for invoking Article 226. When factual adjudication required, Article 226 interference ruled out as held in UOI v. Vicco Labs. Petitioner's reasons agitable before adjudicating authority itself. No grounds to entertain petition under Article 226. Petitioner relegated to pursue statutory remedies. Petition dismissed.
Petitioner challenged SCN alleging conspiracy to issue fake invoices without actual supply using another entity's GST registration for tax evasion. HC held petitioner has remedy to file objection for adjudication on merits. Mere assertion of lack of jurisdiction or abuse of process insufficient for invoking Article 226. When factual adjudication required, Article 226 interference ruled out as held in UOI v. Vicco Labs. Petitioner's reasons agitable before adjudicating authority itself. No grounds to entertain petition under Article 226. Petitioner relegated to pursue statutory remedies. Petition dismissed.
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