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 dismissed petition as infructuous and non-maintainable. The Court noted the petitioner had been summoned under Section 70 of the CGST/GGST Acts, subjected to prolonged questioning and retention followed by arrest, and that Sections 70 and 69 confer summon and arrest powers respectively, with Section 70 inquiries treated as judicial proceedings. Despite factual findings about extensive questioning and a COVID test during the relevant period, the claimed relief became moot during pendency, and the petitioner had not exhausted the efficacious statutory remedy of revision. In view of mootness and availability of an alternative remedy, the petition was disposed of.
HC dismissed petition as infructuous and non-maintainable. The Court noted the petitioner had been summoned under Section 70 of the CGST/GGST Acts, subjected to prolonged questioning and retention followed by arrest, and that Sections 70 and 69 confer summon and arrest powers respectively, with Section 70 inquiries treated as judicial proceedings. Despite factual findings about extensive questioning and a COVID test during the relevant period, the claimed relief became moot during pendency, and the petitioner had not exhausted the efficacious statutory remedy of revision. In view of mootness and availability of an alternative remedy, the petition was disposed of.
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