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 addressed procedural challenge regarding timing of notice issued before expiry of response period to Form GSTR DRC-01A. While petitioner initially contested DRC-01A validity, scope narrowed to requesting underlying materials from authorities. Court affirmed petitioner's right to request documentation and raise jurisdictional objections in response to DRC-01A. Authorities directed to consider such requests per law, ensuring reasonable hearing opportunity. Notably, court preserved petitioner's right to raise all available defenses while maintaining procedural safeguards. Matter disposed with directive to authorities to process any subsequent requests in accordance with statutory provisions.
HC addressed procedural challenge regarding timing of notice issued before expiry of response period to Form GSTR DRC-01A. While petitioner initially contested DRC-01A validity, scope narrowed to requesting underlying materials from authorities. Court affirmed petitioner's right to request documentation and raise jurisdictional objections in response to DRC-01A. Authorities directed to consider such requests per law, ensuring reasonable hearing opportunity. Notably, court preserved petitioner's right to raise all available defenses while maintaining procedural safeguards. Matter disposed with directive to authorities to process any subsequent requests in accordance with statutory provisions.
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