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...
HC allowed condonation of a 26-day delay in filing the appeal, held that the Appellate Authority's summary rejection without affording a hearing violated principles of natural justice and statutory mandates under the Act of 2017 (notably the hearing requirement in Section 75(4) and the duty to pass reasoned orders under Section 107(12)). The HC set aside the impugned summary rejection of the appeal against the ex-parte demand order in Form GST DRC-07 relating to FY 2018-19, concluded there was no mala fide delay, and remitted the matter to the Appellate Authority to grant an opportunity of hearing and pass a fresh, speaking order. Petition disposed by remand.
HC allowed condonation of a 26-day delay in filing the appeal, held that the Appellate Authority's summary rejection without affording a hearing violated principles of natural justice and statutory mandates under the Act of 2017 (notably the hearing requirement in Section 75(4) and the duty to pass reasoned orders under Section 107(12)). The HC set aside the impugned summary rejection of the appeal against the ex-parte demand order in Form GST DRC-07 relating to FY 2018-19, concluded there was no mala fide delay, and remitted the matter to the Appellate Authority to grant an opportunity of hearing and pass a fresh, speaking order. Petition disposed by remand.
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