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 the writ petition challenging service tax recovery and penalties, directing petitioner to pursue appellate remedies. The court distinguished the Amadeus India case involving mandatory pre-show cause notice consultation requirements. Unlike Cosmic Dye Chemical where Tribunal's ruling on limitation period was challenged before SC, present case involved factual determinations better suited for appellate authority review. HC declined to exercise extraordinary writ jurisdiction since alternative remedy was available through statutory appeal mechanism. The court emphasized that issues raised required detailed factual appreciation more appropriate for consideration by appellate forums rather than writ proceedings.
HC dismissed the writ petition challenging service tax recovery and penalties, directing petitioner to pursue appellate remedies. The court distinguished the Amadeus India case involving mandatory pre-show cause notice consultation requirements. Unlike Cosmic Dye Chemical where Tribunal's ruling on limitation period was challenged before SC, present case involved factual determinations better suited for appellate authority review. HC declined to exercise extraordinary writ jurisdiction since alternative remedy was available through statutory appeal mechanism. The court emphasized that issues raised required detailed factual appreciation more appropriate for consideration by appellate forums rather than writ proceedings.
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