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...
Writ petition challenging seizure of goods and imposition of tax and penalty is allowed. The HC quashed the impugned order and, relying on this Court's prior decision and applicable CBIC guidance, directed the respondent to either refund amounts paid by the petitioner or permit adjustment by crediting the petitioner's electronic cash ledger for future tax liability; the order has not been appealed and the issue has attained finality. Consequently, the petitioner is entitled to restitution or tax-credit relief as directed, and the writ issues accordingly.
Writ petition challenging seizure of goods and imposition of tax and penalty is allowed. The HC quashed the impugned order and, relying on this Court's prior decision and applicable CBIC guidance, directed the respondent to either refund amounts paid by the petitioner or permit adjustment by crediting the petitioner's electronic cash ledger for future tax liability; the order has not been appealed and the issue has attained finality. Consequently, the petitioner is entitled to restitution or tax-credit relief as directed, and the writ issues accordingly.
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