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 petition on maintainability grounds, holding that the petitioner has an alternative efficacious remedy by way of appeal under Section 107 of the GST Act. The court found no violation of natural justice, as the petitioner was not entitled to cross-examine departmental officers who issued summons or arrest memos. Further, the petitioner retained the opportunity to make submissions during the appeal proceedings, which are a continuation of the original proceedings. The HC refrained from expressing any opinion on the merits and granted liberty to the petitioner to file the statutory appeal in accordance with law.
The HC dismissed the petition on maintainability grounds, holding that the petitioner has an alternative efficacious remedy by way of appeal under Section 107 of the GST Act. The court found no violation of natural justice, as the petitioner was not entitled to cross-examine departmental officers who issued summons or arrest memos. Further, the petitioner retained the opportunity to make submissions during the appeal proceedings, which are a continuation of the original proceedings. The HC refrained from expressing any opinion on the merits and granted liberty to the petitioner to file the statutory appeal in accordance with law.
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