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 dismisses petition challenging tax demand, finding procedural irregularities in the original order but declining to remand the matter. The court held that the Adjudicating Authority did not fully comply with previous judicial directions and natural justice principles. However, the petitioner is directed to pursue appellate remedies under Section 107 of CGST Act, 2017, with the Appellate Authority empowered to comprehensively examine the input tax credit (ITC) claim and determine the validity of the original demand order. The petitioner remains bound by the appellate determination, subject to available legal recourse.
HC dismisses petition challenging tax demand, finding procedural irregularities in the original order but declining to remand the matter. The court held that the Adjudicating Authority did not fully comply with previous judicial directions and natural justice principles. However, the petitioner is directed to pursue appellate remedies under Section 107 of CGST Act, 2017, with the Appellate Authority empowered to comprehensively examine the input tax credit (ITC) claim and determine the validity of the original demand order. The petitioner remains bound by the appellate determination, subject to available legal recourse.
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