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 dismissed SLP challenging rectification of GST returns beyond prescribed timelines. The court held that the right to correct clerical or arithmetical errors is inherent in conducting business and should not be denied without substantial justification. Software limitations cannot be a valid reason to prevent error correction, as technological systems can be reconfigured to facilitate compliance. The ruling emphasizes taxpayers' procedural flexibility in addressing inadvertent mistakes in tax documentation, affirming the principle of substantive justice over rigid procedural constraints.
HC dismissed SLP challenging rectification of GST returns beyond prescribed timelines. The court held that the right to correct clerical or arithmetical errors is inherent in conducting business and should not be denied without substantial justification. Software limitations cannot be a valid reason to prevent error correction, as technological systems can be reconfigured to facilitate compliance. The ruling emphasizes taxpayers' procedural flexibility in addressing inadvertent mistakes in tax documentation, affirming the principle of substantive justice over rigid procedural constraints.
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