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 dismissed the writ petition for lack of maintainability, holding that the petitioner lacked locus standi to invoke Article 226 jurisdiction. Although the petitioner filed complaints leading to notices by GST and Income Tax authorities, no personal legal injury or infringement of rights was demonstrated. The Court emphasized that Article 226 jurisdiction requires the petitioner to have a personal or individual right affected, except in habeas corpus or quo warranto petitions. Since the petitioner neither suffered legal grievance nor was aggrieved by official inaction, he could not claim to be a person aggrieved entitled to seek mandamus. Consequently, the petition was dismissed as not maintainable for failure to establish a vested right or personal harm.
The HC dismissed the writ petition for lack of maintainability, holding that the petitioner lacked locus standi to invoke Article 226 jurisdiction. Although the petitioner filed complaints leading to notices by GST and Income Tax authorities, no personal legal injury or infringement of rights was demonstrated. The Court emphasized that Article 226 jurisdiction requires the petitioner to have a personal or individual right affected, except in habeas corpus or quo warranto petitions. Since the petitioner neither suffered legal grievance nor was aggrieved by official inaction, he could not claim to be a person aggrieved entitled to seek mandamus. Consequently, the petition was dismissed as not maintainable for failure to establish a vested right or personal harm.
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