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 disposed the writ petition, directing the petitioner to appear before the Additional Assistant Director, DGGI, Bhopal Zonal Unit on 17.09.2025 at 14:30 with all documents relating to the summons/notice purportedly issued under Section 74 of the CGST Act. The AD shall verify the documents and, applying the SC's interpretation of Section 6(2)(b) of the CGST Act - namely that "initiation of any proceedings" denotes formal adjudicatory commencement by issuance of a show-cause notice (and does not include issuance of summons or searches/seizures), and that "subject matter" denotes the specific tax liability or obligation sought to be assessed or recovered - decide whether to proceed further. Petition stands disposed.
The HC disposed the writ petition, directing the petitioner to appear before the Additional Assistant Director, DGGI, Bhopal Zonal Unit on 17.09.2025 at 14:30 with all documents relating to the summons/notice purportedly issued under Section 74 of the CGST Act. The AD shall verify the documents and, applying the SC's interpretation of Section 6(2)(b) of the CGST Act - namely that "initiation of any proceedings" denotes formal adjudicatory commencement by issuance of a show-cause notice (and does not include issuance of summons or searches/seizures), and that "subject matter" denotes the specific tax liability or obligation sought to be assessed or recovered - decide whether to proceed further. Petition stands disposed.
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