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...
The HC declined to adjudicate the constitutional validity of Section 7 of the Taxation and Other Laws (Relaxation and Amendment) Act, 2020, introducing Section 168A in the GST Act, and the related Notifications Nos. 9 and 56 of 2023, as identical issues are pending before the SC. Exercising judicial discipline, the HC refrained from expressing any opinion on the vires of Section 168A or the challenged notifications. The HC directed that the petition be governed by the forthcoming SC judgment, which shall be binding on the parties. Consequently, the petition was disposed of without a substantive ruling on the merits.
The HC declined to adjudicate the constitutional validity of Section 7 of the Taxation and Other Laws (Relaxation and Amendment) Act, 2020, introducing Section 168A in the GST Act, and the related Notifications Nos. 9 and 56 of 2023, as identical issues are pending before the SC. Exercising judicial discipline, the HC refrained from expressing any opinion on the vires of Section 168A or the challenged notifications. The HC directed that the petition be governed by the forthcoming SC judgment, which shall be binding on the parties. Consequently, the petition was disposed of without a substantive ruling on the merits.
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