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 under Articles 226 and 227 for want of maintainability, holding that the petitioner failed to demonstrate sufficient cause for inordinate delay and unjustifiably bypassed the statutory alternative remedy to challenge the impugned order dated 17 August 2024. Allegations concerning excess input tax credit in GSTR-3B vis-Ã -vis GSTR-2A did not justify invocation of discretionary writ jurisdiction absent promptness or exceptional circumstances. Applying established parameters restricting exercise of Article 226 discretion, the Court declined to exercise relief against an assessment/order capable of statutory challenge and accordingly dismissed the petition.
The HC dismissed the writ petition under Articles 226 and 227 for want of maintainability, holding that the petitioner failed to demonstrate sufficient cause for inordinate delay and unjustifiably bypassed the statutory alternative remedy to challenge the impugned order dated 17 August 2024. Allegations concerning excess input tax credit in GSTR-3B vis-Ã -vis GSTR-2A did not justify invocation of discretionary writ jurisdiction absent promptness or exceptional circumstances. Applying established parameters restricting exercise of Article 226 discretion, the Court declined to exercise relief against an assessment/order capable of statutory challenge and accordingly dismissed the petition.
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