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 set aside the impugned orders and quashed the appellate rejection based solely on delay, holding that the petitioner was entitled to a reasonable opportunity to adduce material evidence concerning GST exemption on specified rice transactions. The court directed the petitioner to produce invoices and corroborative evidence within two months and ordered the competent authority to schedule an oral hearing, consider the newly produced material, and pass a fresh speaking order within four months. The matter is remitted for fresh adjudication on merits limited to the exemption claim; petition allowed and prior orders dated 15.04.2025, 27.04.2024 and 28.04.2024 set aside.
HC set aside the impugned orders and quashed the appellate rejection based solely on delay, holding that the petitioner was entitled to a reasonable opportunity to adduce material evidence concerning GST exemption on specified rice transactions. The court directed the petitioner to produce invoices and corroborative evidence within two months and ordered the competent authority to schedule an oral hearing, consider the newly produced material, and pass a fresh speaking order within four months. The matter is remitted for fresh adjudication on merits limited to the exemption claim; petition allowed and prior orders dated 15.04.2025, 27.04.2024 and 28.04.2024 set aside.
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