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 quashed rectification order concerning GST penalty u/s 129(3). Initial penalty of Rs. 22,37,220/- was imposed and paid by petitioner through DRC-03 under explicit protest. Authority subsequently attempted to rectify order making demand 'NIL' u/s 161. Court held that payment under protest cannot be deemed voluntary, and rectification cannot deprive appellant's statutory right to challenge original penalty order. Period between rectification order (08.10.2024) and present judgment excluded from limitation period for filing appeal against original order dated 06.10.2024. Rectification nullified, preserving petitioner's appellate rights against original penalty assessment.
HC quashed rectification order concerning GST penalty u/s 129(3). Initial penalty of Rs. 22,37,220/- was imposed and paid by petitioner through DRC-03 under explicit protest. Authority subsequently attempted to rectify order making demand 'NIL' u/s 161. Court held that payment under protest cannot be deemed voluntary, and rectification cannot deprive appellant's statutory right to challenge original penalty order. Period between rectification order (08.10.2024) and present judgment excluded from limitation period for filing appeal against original order dated 06.10.2024. Rectification nullified, preserving petitioner's appellate rights against original penalty assessment.
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