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 quashed the adjudication and summary orders for failure to consider the petitioner's annual returns for 2018-19 and 2019-20, relying solely on GSTR-2A and GSTR-3B. The court held that the respondents were obligated to evaluate the annual returns, reconcile ITC claims across years, and account for ITC reversals via DRC-03. The impugned order, premised on an alleged excess ITC claim without such comprehensive analysis, was unsustainable. The matter involved factual determinations requiring reappraisal and was accordingly remitted to respondent No. 2 for fresh consideration at the stage of replying to the show cause notice. The petition was allowed by way of remand.
The HC quashed the adjudication and summary orders for failure to consider the petitioner's annual returns for 2018-19 and 2019-20, relying solely on GSTR-2A and GSTR-3B. The court held that the respondents were obligated to evaluate the annual returns, reconcile ITC claims across years, and account for ITC reversals via DRC-03. The impugned order, premised on an alleged excess ITC claim without such comprehensive analysis, was unsustainable. The matter involved factual determinations requiring reappraisal and was accordingly remitted to respondent No. 2 for fresh consideration at the stage of replying to the show cause notice. The petition was allowed by way of remand.
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