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 adjudication order u/s 74(9) of WBGST/CGST Act 2017 and remanded for fresh consideration. The adjudicating authority failed to address key submissions regarding input tax credit claims against supplies from deregistered vendors, particularly concerning retrospective cancellation of supplier registrations and proof of goods movement. The court found procedural deficiencies as the assessing officer did not record findings on precedents cited by assessee. Matter remanded for fresh adjudication with directions to consider all factual issues, legal principles, and grant personal hearing. Appellant permitted to submit fresh reply with supporting documentation and judicial precedents.
HC set aside adjudication order u/s 74(9) of WBGST/CGST Act 2017 and remanded for fresh consideration. The adjudicating authority failed to address key submissions regarding input tax credit claims against supplies from deregistered vendors, particularly concerning retrospective cancellation of supplier registrations and proof of goods movement. The court found procedural deficiencies as the assessing officer did not record findings on precedents cited by assessee. Matter remanded for fresh adjudication with directions to consider all factual issues, legal principles, and grant personal hearing. Appellant permitted to submit fresh reply with supporting documentation and judicial precedents.
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