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 determined the jurisdictional authority of SGST to initiate and adjudicate tax proceedings. The court held that under Section 6(2)(b) of CGST Act, the DGST Department must reconsider the prior appellate order and reassess the show cause notice and subsequent impugned order. The impugned order was set aside, with instructions to place the Commissioner's (Appeals-I) order before DGST for fresh consideration and comprehensive review of the underlying tax matter.
HC determined the jurisdictional authority of SGST to initiate and adjudicate tax proceedings. The court held that under Section 6(2)(b) of CGST Act, the DGST Department must reconsider the prior appellate order and reassess the show cause notice and subsequent impugned order. The impugned order was set aside, with instructions to place the Commissioner's (Appeals-I) order before DGST for fresh consideration and comprehensive review of the underlying tax matter.
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