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 finds that lower authorities failed to adequately examine critical evidence regarding input tax credit (ITC) claim. Despite supplier's subsequent registration cancellation, registration was valid during relevant period. Authorities did not conclusively determine supplier's tax compliance or verify actual goods movement. The court set aside both original and appellate orders, remanding the matter to the adjudicating authority for comprehensive re-examination of documentary evidence and substantive compliance with GST Act provisions, thereby allowing petitioner an opportunity to substantiate ITC claim through proper procedural review.
HC finds that lower authorities failed to adequately examine critical evidence regarding input tax credit (ITC) claim. Despite supplier's subsequent registration cancellation, registration was valid during relevant period. Authorities did not conclusively determine supplier's tax compliance or verify actual goods movement. The court set aside both original and appellate orders, remanding the matter to the adjudicating authority for comprehensive re-examination of documentary evidence and substantive compliance with GST Act provisions, thereby allowing petitioner an opportunity to substantiate ITC claim through proper procedural review.
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