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 GST audit completion timeframe was compliant with Section 65 of CGST Act. Petitioner challenged SCNs under Sections 73 and 74, claiming audit exceeded statutory timeline. Court found additional documents were submitted by petitioner on 09.04.2024, which marked commencement of audit per Section 65 Explanation. Three-month completion requirement ran from this date, not initial notice. Final audit report was filed within prescribed period. While question of whether timeline is mandatory or directory remained open, Court dismissed petition finding audit was timely completed based on actual document submission date. Writ petition dismissed with no merit.
HC determined GST audit completion timeframe was compliant with Section 65 of CGST Act. Petitioner challenged SCNs under Sections 73 and 74, claiming audit exceeded statutory timeline. Court found additional documents were submitted by petitioner on 09.04.2024, which marked commencement of audit per Section 65 Explanation. Three-month completion requirement ran from this date, not initial notice. Final audit report was filed within prescribed period. While question of whether timeline is mandatory or directory remained open, Court dismissed petition finding audit was timely completed based on actual document submission date. Writ petition dismissed with no merit.
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