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 challenging the demand and penalties totaling Rs. 8.83 crores for fraudulent ITC claims involving multiple non-existent firms and numerous noticees for FY 2017-18. The Court held that the petitioner must pursue the statutory appellate remedy rather than seek relief via writ jurisdiction, given the complexity and multiplicity of transactions underlying the ITC claims. The non-consideration of the petitioner's reply does not preclude filing an appeal with supporting documents. The Court noted that consolidated show cause notices were impracticable due to distinct transaction networks. Consequently, the HC declined to adjudicate on the merits under writ jurisdiction and disposed of the petition accordingly.
The HC dismissed the writ petition challenging the demand and penalties totaling Rs. 8.83 crores for fraudulent ITC claims involving multiple non-existent firms and numerous noticees for FY 2017-18. The Court held that the petitioner must pursue the statutory appellate remedy rather than seek relief via writ jurisdiction, given the complexity and multiplicity of transactions underlying the ITC claims. The non-consideration of the petitioner's reply does not preclude filing an appeal with supporting documents. The Court noted that consolidated show cause notices were impracticable due to distinct transaction networks. Consequently, the HC declined to adjudicate on the merits under writ jurisdiction and disposed of the petition accordingly.
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