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 determined that authorities erred in denying transitional ITC claim under CGST Act s.140(5) without providing personal hearing. While petitioner incorrectly filed Form TRAN-1 by entering service tax credit details in column 5(a) instead of 7(a) for invoices received post June 30, 2017, principles of natural justice required opportunity to demonstrate compliance with statutory requirements. Authorities must allow petitioner to prove receipt of amounts after June 30, 2017, recorded in books within 30 days. Matter remanded for fresh consideration with directions to provide personal hearing and issue reasoned order on petitioner's transitional ITC claim. Petition allowed through remand.
HC determined that authorities erred in denying transitional ITC claim under CGST Act s.140(5) without providing personal hearing. While petitioner incorrectly filed Form TRAN-1 by entering service tax credit details in column 5(a) instead of 7(a) for invoices received post June 30, 2017, principles of natural justice required opportunity to demonstrate compliance with statutory requirements. Authorities must allow petitioner to prove receipt of amounts after June 30, 2017, recorded in books within 30 days. Matter remanded for fresh consideration with directions to provide personal hearing and issue reasoned order on petitioner's transitional ITC claim. Petition allowed through remand.
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