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 petition, setting aside the impugned order and remitting the matter back to the 3rd respondent for reconsideration. The court recognized the applicability of the Amnesty Scheme under Section 128(A) of CGST Act for tax years 2017-18, 2018-19, and 2019-20. The decision emphasized that undisputed tax arrears cannot be demanded arbitrarily when express legal provisions exist under Section 75(12) of GST Acts. The petitioner was granted an opportunity to avail the benefits of the Amnesty Scheme, with directions to reconsider the matter in accordance with established legal principles.
HC allowed the petition, setting aside the impugned order and remitting the matter back to the 3rd respondent for reconsideration. The court recognized the applicability of the Amnesty Scheme under Section 128(A) of CGST Act for tax years 2017-18, 2018-19, and 2019-20. The decision emphasized that undisputed tax arrears cannot be demanded arbitrarily when express legal provisions exist under Section 75(12) of GST Acts. The petitioner was granted an opportunity to avail the benefits of the Amnesty Scheme, with directions to reconsider the matter in accordance with established legal principles.
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