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 dismissed petitions challenging territorial jurisdiction of Additional Commissioner, Kanpur to adjudicate show cause notices (SCNs) issued by DGGI Ahmedabad under CGST Act. Petitioners contested jurisdiction based on Circular 169/2022 and Notification 2/2022, arguing Additional Commissioner lacked All-India jurisdiction. Court held that as per Notification 31/2018, Additional/Joint Commissioner has authority to determine tax liability for SCNs issued by DGGI. Court directed petitioners to raise jurisdictional and other contentions during adjudication proceedings, declining to exercise extraordinary writ jurisdiction under Article 226 at this preliminary stage.
HC dismissed petitions challenging territorial jurisdiction of Additional Commissioner, Kanpur to adjudicate show cause notices (SCNs) issued by DGGI Ahmedabad under CGST Act. Petitioners contested jurisdiction based on Circular 169/2022 and Notification 2/2022, arguing Additional Commissioner lacked All-India jurisdiction. Court held that as per Notification 31/2018, Additional/Joint Commissioner has authority to determine tax liability for SCNs issued by DGGI. Court directed petitioners to raise jurisdictional and other contentions during adjudication proceedings, declining to exercise extraordinary writ jurisdiction under Article 226 at this preliminary stage.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
