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 writ appeal challenging refund application under Section 142(3) for unutilized CENVAT credit. The court upheld the Single Judge's ruling, finding the refund claim unsustainable based on Supreme Court precedent and existing statutory provisions. The appellant's arguments regarding refund under Section 55 of CGST Act were rejected as futile. The court determined no interference was warranted with the original judgment, thereby conclusively dismissing the appeal and maintaining the lower court's decision against the refund claim.
HC dismissed writ appeal challenging refund application under Section 142(3) for unutilized CENVAT credit. The court upheld the Single Judge's ruling, finding the refund claim unsustainable based on Supreme Court precedent and existing statutory provisions. The appellant's arguments regarding refund under Section 55 of CGST Act were rejected as futile. The court determined no interference was warranted with the original judgment, thereby conclusively dismissing the appeal and maintaining the lower court's decision against the refund claim.
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