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 the impugned order regarding time limitation and GSTR-3B/GSTR-2A mismatch dispute. The petitioner's willingness to deposit 25% of disputed tax amount was considered favorably. Court granted relief by directing petitioner to deposit the agreed percentage within four weeks from order receipt, allowing a final opportunity to present objections before the adjudicating authority. The decision balances tax compliance requirements with procedural fairness, enabling the petitioner to pursue substantive arguments while ensuring partial tax recovery. Matter remanded for fresh consideration upon compliance with deposit condition.
HC set aside the impugned order regarding time limitation and GSTR-3B/GSTR-2A mismatch dispute. The petitioner's willingness to deposit 25% of disputed tax amount was considered favorably. Court granted relief by directing petitioner to deposit the agreed percentage within four weeks from order receipt, allowing a final opportunity to present objections before the adjudicating authority. The decision balances tax compliance requirements with procedural fairness, enabling the petitioner to pursue substantive arguments while ensuring partial tax recovery. Matter remanded for fresh consideration upon compliance with deposit condition.
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