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 the writ petition challenging tax refund rejection, holding that the petitioner must first exhaust statutory appellate remedies under Section 107 of CGST Act before seeking judicial intervention. The court found the challenge premature, as the underlying adjudication order comprehensively addressed factual issues. The petitioner was directed to pursue the prescribed administrative appeal mechanism, thereby maintaining procedural propriety and preventing premature judicial interference in tax dispute resolution.
HC dismissed the writ petition challenging tax refund rejection, holding that the petitioner must first exhaust statutory appellate remedies under Section 107 of CGST Act before seeking judicial intervention. The court found the challenge premature, as the underlying adjudication order comprehensively addressed factual issues. The petitioner was directed to pursue the prescribed administrative appeal mechanism, thereby maintaining procedural propriety and preventing premature judicial interference in tax dispute resolution.
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