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 allowed petitioner to challenge pre-show cause notice dated 18th July 2024 in Form GSTDRC-01A under Section 74 of WBGST/CGST Act 2017 regarding alleged fraudulent input tax credit availment for 2019-20. Court granted liberty to petitioner to avail Amnesty Scheme benefits under Section 128A before expiry on 30th June 2025, without prejudice to parties' rights in writ petition. If petitioner applies for amnesty benefits, authority shall permit such benefits by treating show cause notice dated 5th February 2025 as issued under Section 73. All subsequent steps including tax deposit shall abide by petition's outcome. Respondent directed to file affidavit-in-opposition within six weeks.
HC allowed petitioner to challenge pre-show cause notice dated 18th July 2024 in Form GSTDRC-01A under Section 74 of WBGST/CGST Act 2017 regarding alleged fraudulent input tax credit availment for 2019-20. Court granted liberty to petitioner to avail Amnesty Scheme benefits under Section 128A before expiry on 30th June 2025, without prejudice to parties' rights in writ petition. If petitioner applies for amnesty benefits, authority shall permit such benefits by treating show cause notice dated 5th February 2025 as issued under Section 73. All subsequent steps including tax deposit shall abide by petition's outcome. Respondent directed to file affidavit-in-opposition within six weeks.
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