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 granted petitioner liberty to file appeal under Section 107 of CGST Act by 15th July, 2025, with mandatory pre-deposit. The court permitted appellate remedy to be adjudicated on merits without limitation bar. The pending decision in Quest Infotech case regarding consolidated show cause notice across multiple financial years shall potentially bind appellate proceedings. The court emphasized procedural compliance and principles of natural justice while addressing fraudulent ITC availment and goods-less invoice issues.
HC granted petitioner liberty to file appeal under Section 107 of CGST Act by 15th July, 2025, with mandatory pre-deposit. The court permitted appellate remedy to be adjudicated on merits without limitation bar. The pending decision in Quest Infotech case regarding consolidated show cause notice across multiple financial years shall potentially bind appellate proceedings. The court emphasized procedural compliance and principles of natural justice while addressing fraudulent ITC availment and goods-less invoice issues.
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