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 remanded the matter concerning IGST refund dispute, setting aside the Deputy Commissioner's order dated 30.08.2024. The court directed the petitioner to file response to the show cause notice by 02.05.2025, mandating the tax authority to provide personal hearing and issue a fresh order in compliance with legal principles. While rejecting jurisdictional challenges, the court set aside the demand order under Rule 96B due to non-retrospective application and insufficient administrative consideration, effectively providing the petitioner an opportunity to present legal arguments before the tax authority.
HC remanded the matter concerning IGST refund dispute, setting aside the Deputy Commissioner's order dated 30.08.2024. The court directed the petitioner to file response to the show cause notice by 02.05.2025, mandating the tax authority to provide personal hearing and issue a fresh order in compliance with legal principles. While rejecting jurisdictional challenges, the court set aside the demand order under Rule 96B due to non-retrospective application and insufficient administrative consideration, effectively providing the petitioner an opportunity to present legal arguments before the tax authority.
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