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 declined to adjudicate substantive challenges to the legislative competence and validity of Sections 69 and 70, observing that the SC has already resolved those issues in a controlling decision addressing CGST officers' powers to summon, seize and obtain production of documents and to arrest persons suspected of tax evasion, and prescribing statutory safeguards in relation to arrest under Section 132. As the petitions' core contention is foreclosed by the SC precedent and the remaining reliefs were not pressed, the writ petitions were dismissed and disposed of. The court's order leaves intact the operative statutory powers and the SC-prescribed arrest safeguards under the CGST framework.
The HC declined to adjudicate substantive challenges to the legislative competence and validity of Sections 69 and 70, observing that the SC has already resolved those issues in a controlling decision addressing CGST officers' powers to summon, seize and obtain production of documents and to arrest persons suspected of tax evasion, and prescribing statutory safeguards in relation to arrest under Section 132. As the petitions' core contention is foreclosed by the SC precedent and the remaining reliefs were not pressed, the writ petitions were dismissed and disposed of. The court's order leaves intact the operative statutory powers and the SC-prescribed arrest safeguards under the CGST framework.
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