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 petition challenging a GST order, holding that the petitioner must first exhaust the statutory remedy of appeal under Section 107 of the GST Act. The court found no exceptional circumstances warranting direct judicial review, emphasizing the need to follow prescribed administrative appellate mechanisms. The petitioner was directed to file an appeal within four weeks, with the appellate authority considering the time spent in HC as valid for potential delay condonation. The petition was disposed of without examining the substantive merits of the original tax dispute.
HC dismissed the petition challenging a GST order, holding that the petitioner must first exhaust the statutory remedy of appeal under Section 107 of the GST Act. The court found no exceptional circumstances warranting direct judicial review, emphasizing the need to follow prescribed administrative appellate mechanisms. The petitioner was directed to file an appeal within four weeks, with the appellate authority considering the time spent in HC as valid for potential delay condonation. The petition was disposed of without examining the substantive merits of the original tax dispute.
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