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 held that the petition is not maintainable insofar as the petitioner failed to show that the officer exercising Section 129(3) of the CGST Act lacked jurisdiction or that "specifying the penalty payable" requires assessment of goods and valuation prior to its specification; prima facie the petitioner did not cooperate in proceedings under Section 129. The writ petition is disposed of with the petitioner directed to exhaust the remedy of appeal before the appellate authority within one month of receipt of the order. The appellate authority is requested to decide the memorandum of appeal within a reasonable period, namely three months from receipt. No stay was granted.
The HC held that the petition is not maintainable insofar as the petitioner failed to show that the officer exercising Section 129(3) of the CGST Act lacked jurisdiction or that "specifying the penalty payable" requires assessment of goods and valuation prior to its specification; prima facie the petitioner did not cooperate in proceedings under Section 129. The writ petition is disposed of with the petitioner directed to exhaust the remedy of appeal before the appellate authority within one month of receipt of the order. The appellate authority is requested to decide the memorandum of appeal within a reasonable period, namely three months from receipt. No stay was granted.
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