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 allowed the Petitioner's appeal, setting aside the Impugned Order-in-Appeal and Rectification Order. The court found that Respondent No. 2 violated principles of natural justice by rejecting the appeal without considering the submitted Power of Attorney and without providing an opportunity to cure procedural defects. The matter was remanded for fresh consideration, with the Petitioner directed to submit self-certified document copies within two weeks. The decision emphasizes procedural fairness and the opportunity to rectify technical non-compliances in administrative appeals under CGST Act, 2017.
HC allowed the Petitioner's appeal, setting aside the Impugned Order-in-Appeal and Rectification Order. The court found that Respondent No. 2 violated principles of natural justice by rejecting the appeal without considering the submitted Power of Attorney and without providing an opportunity to cure procedural defects. The matter was remanded for fresh consideration, with the Petitioner directed to submit self-certified document copies within two weeks. The decision emphasizes procedural fairness and the opportunity to rectify technical non-compliances in administrative appeals under CGST Act, 2017.
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