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, declining to adjudicate the GST liability dispute. The court found significant discrepancies in the petitioner's self-declared turnover values across different documents and inconsistent financial reporting. Citing SC precedent, the court held that the petitioner must first exhaust the alternative statutory remedy by filing an appeal before the Commissioner (Appeals) under Section 107 of the GST Act. The petition was disposed of without examining the substantive merits, directing the petitioner to pursue the prescribed administrative appellate mechanism.
HC dismissed the writ petition, declining to adjudicate the GST liability dispute. The court found significant discrepancies in the petitioner's self-declared turnover values across different documents and inconsistent financial reporting. Citing SC precedent, the court held that the petitioner must first exhaust the alternative statutory remedy by filing an appeal before the Commissioner (Appeals) under Section 107 of the GST Act. The petition was disposed of without examining the substantive merits, directing the petitioner to pursue the prescribed administrative appellate mechanism.
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