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 held that the challenge to Notifications No. 9/2023-Central Tax and No. 56/2023-Central Tax shall be subject to the Supreme Court's pending decision in M/s HCCSEW-MEIL-AAG JV v. Assistant Commissioner of State Tax & Ors. The Court directed the Adjudicating Authority to provide a personal hearing to the Petitioner, consider the previously filed reply to the Show Cause Notice, and issue a fresh reasoned order. The writ petition was disposed of, mandating procedural fairness and an opportunity to be heard in compliance with principles of natural justice.
HC held that the challenge to Notifications No. 9/2023-Central Tax and No. 56/2023-Central Tax shall be subject to the Supreme Court's pending decision in M/s HCCSEW-MEIL-AAG JV v. Assistant Commissioner of State Tax & Ors. The Court directed the Adjudicating Authority to provide a personal hearing to the Petitioner, consider the previously filed reply to the Show Cause Notice, and issue a fresh reasoned order. The writ petition was disposed of, mandating procedural fairness and an opportunity to be heard in compliance with principles of natural justice.
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