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 allowed the writ petition, holding the adjudication order to be a non-speaking order lacking application of mind; the authority had merely rejected the petitioner's reply as "not satisfactory" without addressing the grounds raised. The petition was remitted for de novo adjudication of the show-cause notice under section 74 of the GST Act, with directions that the Assistant Commissioner of State Tax decide the matter on merits, independently and after appreciating the petitioner's contentions, and without being influenced by an earlier advance ruling rendered to a related proprietor which was not challenged. The petition stands allowed by way of remand.
The HC allowed the writ petition, holding the adjudication order to be a non-speaking order lacking application of mind; the authority had merely rejected the petitioner's reply as "not satisfactory" without addressing the grounds raised. The petition was remitted for de novo adjudication of the show-cause notice under section 74 of the GST Act, with directions that the Assistant Commissioner of State Tax decide the matter on merits, independently and after appreciating the petitioner's contentions, and without being influenced by an earlier advance ruling rendered to a related proprietor which was not challenged. The petition stands allowed by way of remand.
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