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...
The HC rejected the writ petition challenging an intimation of tax issued under Section 73(5) of the KGST/CGST Act, 2017 as premature. The Court noted that the intimation merely ascertained tax with options for the petitioner to either pay with interest or file submissions. The document itself provided an opportunity for the petitioner to respond, and no show cause notice under Section 73(1) or final order under Section 73(9) had yet been issued. The Court concluded that judicial intervention was unwarranted at this preliminary stage of the tax assessment process.
The HC rejected the writ petition challenging an intimation of tax issued under Section 73(5) of the KGST/CGST Act, 2017 as premature. The Court noted that the intimation merely ascertained tax with options for the petitioner to either pay with interest or file submissions. The document itself provided an opportunity for the petitioner to respond, and no show cause notice under Section 73(1) or final order under Section 73(9) had yet been issued. The Court concluded that judicial intervention was unwarranted at this preliminary stage of the tax assessment process.
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