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 writ petition challenging tax credit assessment, finding no violation of natural justice. The court noted petitioners failed to substantively contest the main issue of goods supply and input tax credit. While rejecting procedural challenges regarding relied upon documents (RUDs), the HC granted liberty to file an appeal under Section 107 of CGST Act by 15th July, 2025, with mandatory pre-deposit, ensuring merits-based appellate review. The decision emphasizes procedural compliance and substantive argumentation in tax dispute resolution.
HC dismissed the writ petition challenging tax credit assessment, finding no violation of natural justice. The court noted petitioners failed to substantively contest the main issue of goods supply and input tax credit. While rejecting procedural challenges regarding relied upon documents (RUDs), the HC granted liberty to file an appeal under Section 107 of CGST Act by 15th July, 2025, with mandatory pre-deposit, ensuring merits-based appellate review. The decision emphasizes procedural compliance and substantive argumentation in tax dispute resolution.
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