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 dismisses the petition filed by the petitioner summarily for delay, holding that no substantive relief remains as explicit guidelines govern recovery of outstanding dues where first appeal has been disposed of until the Appellate Tribunal becomes operational. The Court reserves liberty for the petitioner to comply with Circular No. 224/18/2024-GST by filing an undertaking with the jurisdictional officer to institute an appeal before the Appellate Tribunal when it becomes operational within the time prescribed under Section 112 of the CGST Act and to remit the prescribed pre-deposit under Section 112(8) within 30 days of receipt of this order. Upon filing such undertaking, recovery of the remaining amount shall be stayed pursuant to Section 112(9). Petition disposed.
HC dismisses the petition filed by the petitioner summarily for delay, holding that no substantive relief remains as explicit guidelines govern recovery of outstanding dues where first appeal has been disposed of until the Appellate Tribunal becomes operational. The Court reserves liberty for the petitioner to comply with Circular No. 224/18/2024-GST by filing an undertaking with the jurisdictional officer to institute an appeal before the Appellate Tribunal when it becomes operational within the time prescribed under Section 112 of the CGST Act and to remit the prescribed pre-deposit under Section 112(8) within 30 days of receipt of this order. Upon filing such undertaking, recovery of the remaining amount shall be stayed pursuant to Section 112(9). Petition disposed.
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