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 set aside the impugned order and remitted the matter for fresh consideration by respondent No.4, who had rejected petitioner's claim under various GST circulars solely on grounds of insufficient documentation. The court determined that petitioner should be given another opportunity to file additional pleadings and documents for reconsideration. Following reassessment, petitioner would be entitled to apply for benefits under the Amnesty scheme under Section 128A of the CGST Act, which the concerned respondent must consider in accordance with law. The court refrained from expressing any opinion on the substantive merits of the rival contentions.
The HC set aside the impugned order and remitted the matter for fresh consideration by respondent No.4, who had rejected petitioner's claim under various GST circulars solely on grounds of insufficient documentation. The court determined that petitioner should be given another opportunity to file additional pleadings and documents for reconsideration. Following reassessment, petitioner would be entitled to apply for benefits under the Amnesty scheme under Section 128A of the CGST Act, which the concerned respondent must consider in accordance with law. The court refrained from expressing any opinion on the substantive merits of the rival contentions.
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