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 issues writ of certiorari quashing the adjudication order of respondent authorities and allows the petition. The court held that non-claim of ITC in 2018-19 and its subsequent claim in 2019-20 (including RCM amounts) could be reconciled from records already in the possession of the Revenue, and such reconciliation did not hinge on the petitioner's response to the show-cause notice. Consequently, the impugned adjudication lacked basis and was set aside. The adjudicatory order of respondent No.2 is quashed and the petition is allowed.
HC issues writ of certiorari quashing the adjudication order of respondent authorities and allows the petition. The court held that non-claim of ITC in 2018-19 and its subsequent claim in 2019-20 (including RCM amounts) could be reconciled from records already in the possession of the Revenue, and such reconciliation did not hinge on the petitioner's response to the show-cause notice. Consequently, the impugned adjudication lacked basis and was set aside. The adjudicatory order of respondent No.2 is quashed and the petition is allowed.
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